PRIVACY POLICY

Last Updated: January 2026

Optimax Investment Ltd. together with its subsidiaries, affiliates, or related companies (collectively, the “Company”, “Optimax”, “GlassesUSA”, “our”, “we” or “us”), provides its customers and potential customers ("Customer", “you” or “your”) with ecommerce websites, such as: www.glassesusa.com , m.glassesusa.com and www.ottica.com as well as any other websites, mobile sites, (our “Sites”) and mobile applications (our “Apps”) (collectively , our “Properties”) owned, operated and/or distributed by the Company, as well as our provision of products and services provided or made available by GlassesUSA through which we provide personally tailored offers for eyecare and eyewear products and associated services (collectively, our “Services”).

This Privacy Policy (“Privacy Policy"), including the Cookie Policy, forms an integral part of our Terms of Use.

As we are committed to protecting your rights to privacy, this Privacy Policy further explains how we safeguard your information we collect or to which we may have access, through your use of our Properties, the Services or otherwise through marketing campaigns, how such information may be used or shared with others, and how you may exercise your rights related to your Personal Information (as defined below), all subject to applicable laws.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE ACCESSING AND USING OUR PROPERTIES OR SERVICES. BY ACCESSING OR USING OUR PROPERTIES OR SERVICES YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY. IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS OR USE THE SERVICES.

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

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 Properties 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 state otherwise.

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 sensitive information under applicable law.

“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 deidentified data.

See below details of the types of information we collect, access, share or use, and the purpose for processing such information:

Contact Communications:
When 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.
Purpose of collection:
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.

Checkout and Account Registration:
When placing an order, you may decide to create an account or continue as a guest. During the transaction, we process your full name, age, date of birth, language preference, email address, items you chose, saved items, shopping history, your address, phone number and any information associated with the transactions, including payment information or health insurance information, as further detailed below.
We will also collect information pertaining to shipping, delivery, postage, billing and other information used to transact and deliver through the Platform, and where applicable, information required to clear customs (such as Tax ID or other identification numbers). Additionally, if you choose to register and create an account, during the registration process you will be required to create a password. This information will be processed when you login as well, so please keep your credentials secure and confidential.
I If you choose to sign in through your social accounts (e.g., Google or Facebook account), certain Personal Information about you will be shared with us. You have the ability to control the Personal Information to which you allow access through the privacy settings on the applicable social platforms and the permissions you give us. By associating an account managed by a social platform with your account and authorizing us to have access to this information, you agree that we may collect, use and retain the information provided by these social platforms in accordance with this Privacy Policy.
Purpose of collection:
We use this information to provide our Service, send you the items you requested, to personalize and customize the Services and improve the Services. We use such information to create and designate your account,authenticate and validate access, enable log-in, access and use of your account as well as to send you needed information related to our engagement (e.g., send you a welcome message, notify you regarding any updates to your orders, send applicable invoices, etc.)
By registering to or providing us with your e-mail address or any other contact information, you hereby agree that we may contact you for the purpose of informing you regarding our Services which may interest you, and to send to you other marketing material. You may opt-out by sending an email to the following address: privacy@glassesusa.com or by pressing the "Unsubscribe" button contained in the promotional communications you receive.
Please note that we may also contact you with essential information regarding your use and interaction with our Services, you will not be able to opt-out of receiving such service messages.
We use the transaction information to profile you, and your preference so we can offer you items we think you will like.
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 and/or disclose additional information as detailed in the Notice of Privacy Practice.
Purpose of collection:
We use any of this information to provide you with the Services and process the payments of the eye-products you have purchased.

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.
Purpose of collection:
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 ourServices, protecting against harm to the rights, property or safety of ourProperties, users, or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Privacy Policy; oor 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).

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 which we perform such automatic collection through use of tools that measure the advertisement, the content viewed, the emails (if you opened it or not), 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 – i.e., to send you a reminder emailthat you have not completed your order of the items you added to your cart, and to build a profile on you in order to present you offers which are tailor made to your preferenc. 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.
Purpose of collection:
We perform automatic collection of users’ data through the use of tools that measure the advertisement, the content viewed, the emails (if you opened it or not), all to obtain insights on how our campaigns optimize and convert, measure the performance of our Services and ad campaigns, measure the performance of our marketing efforts, etc. Further, we use your online behavioral information to market our Properties and Services – for example, to send you a reminder email that you have not completed the purchasing of the items that were added to your cart, to build a profile about you in order to present you with offers which are tailor-made to your preference, to provide you with offers which we believe you might find interesting based an offer you previously redeemed, etc. To the extent we’re permitted to do so under applicable law, we intend to send you marketing and advertising material and general and personalized content and to track and analyze the effectiveness and relevance of such material. We may also ask for your consent to send you other kinds of marketing offers and communications.

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. These 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.
Purpose of collection:
We use web analytics tools to enhance the experience by optimizing the efficiency, design, and quality of oWe 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 such as measure the success of our marketing efforts, and compile statistics about usage of the Services and response rates. 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 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, these tools allow us to provide you with a more seamless, customer-centric e-shopping experience while on the Properties. For more information about this session replay software, see FullStory’s Privacy Policy at FullStory’s Privacy Policy and Microsoft Clarity Data Privacy.

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.
Purpose of collection:
We use such information to improve our Services and allow others to make an informed decision prior to purchasing a specific product. You agree that we may collect, use and retain the contents of such review and your image, including for purposes of publicly displaying such information within the Properties and our marketing assets.

Social Media Interaction:
We allow you to share certain information with social media 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 /post for branding purposes.
Purpose of collection:
Our Legitimate Interest in connection with promotional activities. For example, if you post #GlassesUSA in connection with one or more of ourProducts or Services across social media, we reserve the right to track, retain and use a copy of the post/tweet. 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

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.
Purpose of collection:
We use this information 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.

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.
Purpose of collection:
We will use your phone number to provide you with the Services and to send you 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 or by clicking the link in the text message, whichever is available to you. Once you have 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.).

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 App, we will request the following permissions: GPS, camera, photos, Bluetooth signals, and information about nearby Wi-Fi access (“App Permissions”).
Purpose of collection:
We use this information to provide and enhance our Properties and Services. To access these App Permissions, you will need to actively and explicitly enable them through in-app permission or the mobile setting. 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.

Purposes: To provide you and other visitors ofour Properties 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.

In addition, our Pairfect Match™ quiz operates, in part, through the integrated technology of Perfect. We may use the VTO Input Data to offer you personalized eyewear recommendations when you request to take the Pairfect Match™ quiz through our Properties.

Any VTO Input Data that is collected, stored, or used will be solely for these purposes. In the event GlassesUSA or Perfect begins collecting VTO Input Data for any additional purpose, we will update this Policy.

Disclosure
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.

Retention/Destruction
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. 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 when you create an Account, place and order, contact us, provide a prescription, 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.

We use “cookies” and similar tracking technologies such as Software Developer Kits (SDKs) when you access, interact with, or use any of 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 device while you are visiting 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 www.allaboutcookies.org.
Our Cookie Policy, available here , details the tracking technologies we use on our Properties.

Currently, we use the following SDK in our App: AppsFlyer, Firebase, Sentry, Luna and Cloudbees Rollout. 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 PHI to a family member, other relative, close personal friend, or any other person you identify, solely for 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 across social media platforms when either you authorize us to do so, or you actively shareyourPersonal Information on any such platforms regarding our Products and 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 amongst 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 or capital stock, 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 by prominent notice on one or more of our Properties.

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 expressly requests 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.

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. 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. To access, interact with or use our Products or 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 isare 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 Products or 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.

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your Personal Information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

In the table below, you can review how different categories of Users may exercise their rights or if and when Optimax sells or shares a User’s Personal Information, how he/she may opt-out.

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 Information, 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 PersonalInformation we collected from you, and 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 Information 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. You have the right to opt out of the sale of your 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 and/or any 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 in direct exchange for money or some other form of payment, however, we do share Personal Information for analytic and marketing purposes, including targeted advertising, when we promote our Properties or products. In most cases we obtain 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 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 engage in any discriminatory practices concerning our users. .

Below we will provide jurisdiction specifications on how and if the rights below apply to you, depending on your residency and how to exercise your rights. In addition to your rights subject to state laws, if we process PHI, you have additional rights under HIPAA which are detailed here: https://www.glassesusa.com/privacy-practices. This section applies only to California residents pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) which came into effect in November 2020 and was amended by the CPRAon 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 thePersonal Information is shared for a business purpose, whether the Personal Information is sold 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. 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.

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. 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.

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. 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.

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 .

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”. 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 . We make no representation that any of our Properties, Products or Services is appropriate or available for use outside of the United States and Canada. Access to our Properties and the Services therewith may not be legal by certain persons or in certain countries. Those who choose to access our Properties from other locations do so at their own initiative and are responsible for compliance with applicable local laws.

THE ARBITRATION AGREEMENT SET FORTH IN OUR TERMS OF USE IS EXPRESSLY INCORPORATED HEREIN BY REFERENCE AND EQUALLY APPLIES TO ANY DISPUTES ARISING UNDER THIS PRIVACY POLICY. EXCEPT AS OTHERWISE SET FORTH IN THE ARBITRATION AGREEMENT, ANY CLAIM RELATING TO OUR PROPERTIES, PRODUCTS AND/OR SERVICES SHALL BE GOVERNED BY THE INTERNAL LAWS OF THE STATE OF DELAWARE AND THE LAWS THE UNITED STATES OF AMERICA APPLICABLE THEREIN, WITHOUT REFERENCE TO ANY CHOICE OF LAW PROVISIONS. SUBJECT FURTHER TO THE ARBITRATION AGREEMENT IN OUR TERMS OF USE, YOU HEREBY IRREVOCABLY CONSENT TO THE EXCLUSIVE JURISDICTION AND VENUE OF THE FEDERAL OR STATE COURTS IN THE STATE OF DELAWARE FOR ANY CLAIMS THAT ARE NOT ARBITRATED, AND IRREVOCABLY AGREE THAT ALL SUCH CLAIMS WILL BE HEARD IN SUCH COURT. YOU AGREE THAT A FINAL JUDGMENT IN ANY SUCH ACTION OR PROCEEDING SHALL BE CONCLUSIVE AND MAY BE ENFORCED IN OTHER JURISDICTIONS BY SUIT ON THE JUDGMENT OR IN ANY OTHER MANNER PROVIDED BY LAW.

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 .

Your privacy matters

GlassesUSA.com uses cookies, script code, session replay software, and similar tracking technologies to collect data, track site usage and monitor your interactions on our sites to improve user experience. By continuing using our sites, you consent to our use of these technologies and agree to our Terms and Conditions and Privacy Policy (including arbitration). To manage your selections, please see our .