OPTIMAX PRIVACY POLICY

If you are a California resident, please refer to our California Data Privacy Notice.

Optimax Investment Ltd., a company organized under the laws of the State of Israel (together with its subsidiaries, affiliates, and/or related companies) (“GlassesUSA”, “Company”, “our”, “we” or “us”), provides its customers and potential customers (“you”, “User”, “your”) with access to its websites located at www.glassesusa.com and m.glassesusa.com (“Website”) and if applicable, to its mobile application (the “App” and together with the Website, the “Properties”), through which we provide personally tailored offers for eyecare and eyewear products and associated services (“Services”).

This Privacy Policy, including our Cookie Policy below, form an integral part and should be read in conjunction with our Terms of Use.

As we are committed to protecting your rights to privacy, and we make available this Privacy Policy (the "Privacy Policy") to describe our practices regarding the information we may collect or to which we may have access, through your use of our Website, App and Services (together the “Platform”) and the manner in which we may use such information, and the choices and rights available to you.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE ACCESSING AND USING OUR PLATFORM. BY ACCESSING OR USING OUR PLATFORM 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. PLEASE NOTE -- YOU ARE NOT OBLIGATED BY LAW TO PROVIDE US WITH ANY PERSONAL 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, or may be of a private or sensitive nature relating to an identified or identifiable natural person. 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. Personal information does not include information that has been anonymized or aggregated; provided, that, such information can no longer be used to identify a specific natural person.

Personal Information you provide to us when you use our Platform. We collect personal information from you and any devices (including mobile devices) you use when you: use or access our Platform, register for an account with us, provide us information on a web form or other text field, update or add information to your account, or through correspondence that you exchange with us from time to time. More specifically, we collect and use the following categories and types of personal information when you use our Platform:

• Contact information such as your name, email and physical addresses, or telephone number when you complete our online form, register for an account with us or otherwise when you update your accounts details.
• Information you provide during a transaction, or other transaction-based content that you generate or that is connected to your use of the Platform as a result of a transaction you are involved in such as your eyeglasses prescription.
• Other content that you generate, or your account activities (e.g., adding items to your shopping cart, adding items to your saved items list, etc.).
• The contents of your interaction with our customer support or sales departments, which may include text/video/audio recording and transcripts of such communications.
• Financial information (such as credit card or bank account numbers), which is processed by our third-party services providers as further detailed below and to which we generally have no access.
• 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).
• Information you voluntarily provide to the Platform to personalize your Platform interface, such as age,date of birth, preferred language, preferences etc.
• When you complete a survey. or interact with our E-mail newsletters, such as age and date of birth.

Usage Data: You may also provide us information through your use of certain tools, features and applications that we make available to you through the Platform such as chats with support representatives, uploading your picture through use of our “Try on” feature, or when you otherwise communicate with us via the Platform. One such feature is our proprietary “Prescription Scanner” which allows Users to scan their prescription glasses in order to extract the optical parameters of their prescription, and to receive various measurements associated with their prescription (e.g., sphere (power), cylinder (astigmatism), and axis. We also offer Users a tool to determine the distance between pupils (in millimeters rounded to 0.5mm) (“PD”) by analyzing a picture uploaded to the Platform.

Information Mandated by Applicable Law: Information we are required or otherwise authorized to collect under applicable laws to authenticate or identify you or to verify the information we have collected from you via our Platform.

Impression Information: Information about your impressions of, and reactions to, advertisements that appear on the Platform that we receive from devices (including mobile devices) and software you use when you access our Platform. 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 your mobile device or as can be derived from your IP address.

Personal information collected from other sources: We may also collect personal information about you from third parties who have represented to us that they have obtained your consent for such provision of information or that you have freely and publicly provided. For example, we may collect and use demographic and other information that is publicly available and information from credit bureaus, to the extent permitted by applicable law.

Social Media: We allow you to share information with social platforms, or use social platforms to create your account or to connect your account with the respective social platforms. Those social platforms may give us automatic access to certain personal information retained by them about you (e.g., content viewed by you, content liked by you, and information about the advertisements you have been shown or have clicked on, etc.). 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 when you grant us access to your personal information that is being retained by such social platforms. 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. 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.

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.

Submitting a Review: You may be able to submit a review regarding your satisfaction of our products (including through our Third Party Service Providers that enables such surveys, e.g. Trustpilot). In connection with submitting a review, you may share information such as rating, free text and a photos you actively share when submitting such review. You agree that we may collect, use and retain the contents of such review, including for the purposes of publicly displaying such information within the Website and our marketing assets.

Device Information: 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:

• Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
• Device operations: 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).
• Identifiers: unique identifiers, device IDs, and other identifiers.
• Device signals: Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.
• Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.
• Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, and information about other devices that are nearby or on your network.
• Cookie data: data from cookies stored on your device, including cookie IDs and settings. Learn more about how we use cookies, please review our Cookie Policy below.

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 Platform, within our advertising or email content, as further detailed in Section 5. For more information about our use of these technologies, and how to control them, see our Cookies Policy. If you give us personal information about someone else, you must do so only with that person’s express authorization. We collect, process and use your information for the purposes described in this Privacy Policy, based at least on one of the following legal grounds:

When Performing the Services: We collect and process your Personal Information to provide you with the Services, following your acceptance of this Privacy Policy; to maintain and improve our Services; to develop new services and features for our Users; and to personalize the Services in order for you to get a better user experience. For example, we may send you offers and products which we think will be more relevant to your taste, based on your browsing habits across our Platform.

Legitimate interests: 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.

Customer Profiling: We and/or third party service providers that we engage may create general/generic customer profiles based on the information we collect from your use of our Services, and this information may be shared with and/or used by third party platforms to source new customers who bear similar profiles.

Advertising: 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 advertisement via the Platform, email, postal mail, telephone, mobile devices and/or when you visit other sites, and to track and analyze the effectiveness and relevance of such material.

Registration: We may use the order information you provide us for various purposes, including without limitation, marketing, security and account administration. In regard to our use of your information for marketing purposes (including, but not limited to, email marketing), you’ll have the ability to opt-out by following the opt-out procedures described in each marketing communication that you receive.

With your consent: From time to time, we may ask for your consent to process your information for specific purposes, and you have the right to withdraw your consent at any time in the manner described in Section 7 below. For example, we may ask for your consent to send you our marketing offers and communications. From time to time, and subject to applicable laws and regulations, we may obtain your consent by offering you incentives, financial or otherwise, such as discounts and/or credits on future purchases on the Website. Even after providing you with such incentives, you may still withdraw your consent at any time.

• To provide and improve our Platform and its various functions and features and to manage our business;
• To send you updates, notices, notifications, announcements, and additional information related to the Platform;
• To conduct surveys regarding our services or regarding the experience of users in our Platform;
• To be able to manage your account and provide you with customer support and technical assistance;
• To create cumulative statistical data and other cumulative information and/or other conclusive information that is non-personal, in which we might make use, in order to operate and improve our Platform;
• To verify your eligibility and deliver prizes in connection with promotions and referral programs we may hold from time to time;
• To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities, including any breaches of this Privacy Policy or of our Terms of Use; and
• To comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates.

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.

In addition, our the 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:

1. first obtaining informed electronic/written consent from the customer/visitor to do so;
2. the data completes a financial transaction requested/authorized by the customer/visitor;
3. disclosure is required by law or ordinance; or
4. 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. We maintain personal information that we collect from our users in secured cloud storage environments provisioned by third party cloud providers in the United States. Information regarding the Users 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.

It’s our policy, irrespective of the jurisdictions wherein our Users are located, to maintain all User-supplied data in secure environments provisioned by third parties that: (i) have assured us of the safeguards which they implement to protect your rights to privacy, including where applicable, by undertaking to comply with the EU Standard Contractual Clauses; (ii) where applicable, hold and process such information on our behalf in jurisdictions which have been determined to ensure an adequate level protection by the EU Commission, or (iii) perform such processing pursuant to your consent and acceptance of such third-parties privacy policy as further detailed in this Privacy Policy. By providing your information, you expressly consent to the place of storage and transfer described above, including transfers outside of the jurisdiction in which the information was provided. 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, 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 (collectively, "Third Party Service Providers"). Any disclosure or access to personal information is strictly subject to the recipient's or user's undertaking of confidentiality and appropriate safeguards obligations. Our Third Party Service Providers may be divided into two types of third parties:

(i) third parties providing us with services who act as our processors and may only process your personal information according to our instructions (which are made in accordance with the terms hereof). We remain responsible for any personal information processing done by such Third Party Service Providers on our behalf not in accordance with the terms hereof, except for events outside of its reasonable control and except for such Third Party Service Providers with whom you have a direct contractual relationship; and

(ii) third parties providing us with services who act as data controllers with respect to some or part of the information they receive from us, i.e. they may determine the purposes and means of the processing of personal information. Optimax shall have no responsibility or liability with respect to such processing by such third parties. Please see our Cookie Policy below, and our Privacy Preferences Center, for information on how you can opt-out from sharing information with some of our third-party service providers.

By choosing not to opt-out, you agree that any processing of your personal information by such third parties shall be done pursuant to your acceptance and agreement to their terms of use and privacy policies as specified in their relevant properties.

Governmental/Law Enforcement Agencies and Legal Requests or Duties: We may disclose or otherwise allow access to Personal Information pursuant to a legal requirement or request, such as a subpoena, search warrant or court order, or in compliance with applicable laws and regulations. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

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 Users, 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. You can make choices regarding our collection and use of the personal information you share with us. You can control your personal information that we have obtained by emailing the Company at privacy@glassesusa.com. By way of example, you may request (i) access to the personal information we’ve collected from/about you, (ii) that updates are made to your personal information, (iii) that we cease using your personal information to contact you, and (iii) we delete the personal information about you in our records. We will undertake to respond to your request within 30 days of receipt thereof. In some cases, your ability to access or control your personal information will be limited, as required or permitted by applicable law. If that should happen, the Company will notify you accordingly. How you can access or control your personal information will also depend on which Services you use. For example, if you ask us to delete your personal information, we may not be permitted to do so if you’ve made a purchase via our Platform. We will retain your information for as long as your account is active or as needed to provide you access to the Services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and to enforce our agreements.

For the removal of doubt, we expressly reserve the right to transfer, share or otherwise use non-personally identifiable information (e.g., anonymous, aggregated information) in our sole discretion and without the need for further approval. By registering to our Services and/or providing us with your e-mail address or any other contact information (including without limitation through any form on our Website), you hereby agree that we may contact you for the purpose of informing you regarding our products and services which may interest you, and in order to send to you other marketing material. You may withdraw your consent by sending us written notice by email to the following address: privacy@glassesusa.com or by pressing the "Unsubscribe" button contained in the promotional communications you receive. Please note that the Company may also contact you with important information regarding your use and interaction with our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, payment issues, service maintenance, etc. You will not be able to opt-out of receiving such service messages. We use web analytics tools to enhance our users’ experience by optimizing the efficiency, design, and quality of our Website and other Properties. Our analytics tools use cookies and similar technologies to collect and analyze information related to user behavioral metrics on our Website and 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 Website and Properties and they allow us to, for example, identify and repair technical errors, such as broken links that hamper the Website’s/Properties’ functionality. These web analytics tools also help us reconstruct the user experience to better understand, for example, where users may be encountering frustration or impediments to using the Website and/or other 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 software 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 (desktop/tablet/phone), screen resolution, visitor type (first time/returning), anonymized IP address, location (city/country), language, and similar metadata. This software does not collect information on pages where it is not installed, nor does it track or collect information outside your web browser.

We use this web-based analytics software because it provides us with a tool to track the online behavior of visitors while on the Website and other Properties and lets us replay visitors’ actions. This tool gives us the opportunity to make the Website and Properties better and, in turn, provide you with an enhanced online experience as well. Thanks to this tool, we are able to obtain insights on how you and other visitors use the Website and other Properties; for example, whether you can easily locate certain pages or whether it takes multiple clicks to get to those pages. Information about these small choices and interactions are of paramount value to us, as they can easily make your experience better and far more intuitive and, 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.

In addition, Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of our Website and other Properties (including email recipients), measure the success of our marketing efforts, and compile statistics about usage of the services and response rates. By opting-in to receive text messages from us or by sending us an initial text message, you agree to receive recurring text messages (i.e., SMS and/or MMS messages) from GlassesUSA.com, some of which may be considered marketing and may be delivered by us using autodialer systems/technologies. You also represent that you are the owner or authorized user of the mobile device that you used to subscribe for our mobile communications and that you are authorized to approve the applicable charges and rates resulting from such SMS and/or MMS messages. Message and data rates may apply. You (and not GlassesUSA.com) will be responsible for all messaging and data charges that may apply. Standard messaging rates apply to your entry or submission message to any GlassesUSA.com text message service, our confirmation and all subsequent text message correspondence. Please contact your wireless carrier for information about your messaging and data plans. Your consent to receive text messages is not a condition of purchase. Carriers are not liable for delayed or undelivered messages. Message frequency may vary.

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.

You can opt-out of receiving text messages from us at any time by texting “STOP” from the mobile device receiving the messages. If you choose to opt-out you will be unsubscribed from the text program. You will receive one SMS that confirms you have successfully opted-out. After that you will receive no further messages for this system unless/until you opt-in again. For additional help, you may always contact us by sending an email to privacy@glassesusa.com. For HELP, text “HELP” from the mobile device receiving the messages.

In addition, GlassesUSA has rolled-out a feature that offers customers a convenient one-click option to re-order contact lenses. For those users who wish to use this feature and enroll, GlassesUSA will send you automated text messaging reminders as and when it’s time to place an order for contact lenses. We reserve the right to include other GlassesUSA marketing messages and promotions together with any of the reminder text messages that are sent to you. You always have the right to stop receiving contact lense reorder reminder text messages by replying “STOP” to any such message, as we’ve noted above.

Please know that, even if you opted out of receiving text messages from us, we may still contact you for transactional or informational purposes. Some examples are contacts for customer service, product information, service or reminder notices. We may also need to contact you with questions or information regarding your order. Moreover, we reserve the right, at all times, to disclose any mobile messaging data you share with us as necessary to satisfy any law, regulation or governmental request, to avoid liability and/or to protect our rights or property. Except with respect to Users who are accessing the Website in their capacity as insured and\or covered members of a health or other benefit plan (“Covered Members”), the Properties and Services are in essence, a consumer e-commerce platform, which are not subject to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). However, as we take the confidentiality of your health information very seriously we choose to adopt the strict rules of HIPAA in maintaining the privacy of Protected Health Information as such term is defined under the HIPAA ("PHI") and to provide notice of our assumed duties and privacy practices regarding PHI. PHI is information that may identify you and that relates to your past, present, or future physical or mental health or condition, the provision of health care products and services to you or payment for such services. This Notice describes how we may use and disclose PHI about you, as well as how you obtain access to such PHI. This Notice also describes your rights with respect to your PHI.

Treatment: We may use and disclose your PHI to provide and coordinate the treatment and services you receive. For example, we may disclose PHI to pharmacists, doctors, nurses, optometrists, and other personnel involved in your health care. This helps to coordinate your care and make sure that everyone who is involved in your care has the information that they need about you to meet your health care needs.

Consent to Use Vision and Prescription Information related to contact lenses: If you make a purchase of contact lenses, we may request information from you about your medical history, vision, and prescriptions provided to you by a doctor or optometrist (collectively “vision and prescription information”) to complete the transaction and provide you with the product(s) you have purchased. In addition, we may use your vision and prescription information to contact your prescriber for the purpose of requesting that your prescriber furnish a copy of your prescription to us. By providing your vision and prescription information to GlassesUSA.com, you agree and authorize GlassesUSA.com to use your vision and prescription information for the purpose of requesting that your prescriber furnish a copy of your prescription to GlassesUSA.com.

Payment: We may use and disclose your PHI in order to obtain payment for the health care products and services that we may provide to you and for other payment activities related to the services that we provide. For example, we may contact your insurer, pharmacy benefit manager or other health care payor to determine whether it will pay for health care products and services you need and to determine the amount of your co-payment. The information on or accompanying the bill may include information that identifies you, as well as information about the services or products that were provided to you. We may also disclose your PHI to other health care providers or HIPAA covered entities you are associated with, who may need it for their payment activities related to their engagement with you.

Healthcare Operations: We may use PHI to improve the Properties and Services, for marketing activities permitted under HIPAA (such as suggesting a health-related product that we make available to our Users, either on our website or through personalized advertising based on your past purchases), and for our customer service activities, quality improvement, performance evaluation, and other internal business management purposes. We may use your PHI to create de-identified data, which is stripped of your identifiable data and no longer identifies you.

• Business Associates: We may contract with third parties to perform certain services for us, such as billing services, copy services or consulting services. These Third Party Service Providers, referred to as Business Associates and/or Business Associate Subcontractors, may need to access your PHI to perform services for us and in such case we will use our best efforts to ensure they are required by contract and law to protect your PHI and only use and disclose it as necessary to perform their services for us.
• To Communicate with Individuals Involved in Your Care or Payment for Your Care: 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 care 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.
• Reorders: To send you reminders for re-orders (e.g., re-orders of contact lenses), as described above.
• Food and Drug Administration ("FDA"): We may disclose to persons under the jurisdiction of the FDA, PHI relative to adverse events with respect to drugs, foods, supplements, products and product defects, or post-marketing surveillance information to enable product recalls, repairs, or replacement.
• Worker's Compensation: To the extent necessary to comply with law, we may disclose your PHI to worker's compensation or other similar programs established by law.
• Public Health: We may disclose your PHI to public health or legal authorities charged with preventing or controlling disease, injury, or disability, including the FDA. In certain circumstances, we may also report work-related illnesses and injuries to employers for workplace safety purposes.
• Law Enforcement: We may disclose your PHI for law enforcement purposes as required or permitted by law for example, in response to a subpoena or court order, in response to a request from law enforcement, and to report limited information in certain circumstances.
• As Required by Law: We will disclose your PHI when required to do so by federal, state or local law.
• Health Oversight Activities: We may disclose your PHI to an oversight agency for activities authorized by law. These oversight activities include audits, investigations, inspections, and credentialing, as necessary for licensure and for the government to monitor the health care system, government programs and compliance with civil rights laws.
• Judicial and Administrative Proceedings: If you are involved in a lawsuit or a dispute, we may disclose your PHI in response to a court or administrative order. We may also disclose your PHI in response to a subpoena, discovery request, or other lawful process instituted by someone else involved in the dispute, but only if efforts have been made, either by the requesting party or us, to first tell you about the request or to obtain an order protecting the information requested.
• Fund raising: As permitted by applicable law, we may contact you to provide you with information about our fundraising programs. You have the right to "opt out" of receiving these communications and such fundraising materials will explain how you may request to opt out of future communications if you do not want us to contact you further for fundraising efforts.

• Obtain a paper copy of the Notice upon request. You may request a copy of our current Notice at any time. Even if you have agreed to receive the Notice electronically, you are still entitled to a paper copy. You may obtain a paper copy at the site where you obtain health care services from us or by contacting privacy@glassesusa.com.
• Request a restriction on certain uses and disclosures of PHI. You have the right to request additional restrictions on our use or disclosure of your PHI by sending a written request to privacy@glassesusa.com. We are not required to agree to the restrictions, except in the case where the disclosure is to a health plan for purposes of carrying out payment or health care operations, is not otherwise required by law, and the PHI pertains solely to a health care item or service for which you, or a person on your behalf, has paid in full.
• Inspect and obtain a copy of PHI. With a few exceptions, you have the right to access and obtain a copy of the PHI that we maintain about you. If we maintain an electronic health record containing your PHI, you have the right to request to obtain the PHI in an electronic format. To inspect or obtain a copy of your PHI, you must send a written request to privacy@glassesusa.com. You may ask us to send a copy of your PHI to other individuals or entities that you designate. We may deny your request to inspect and copy in certain limited circumstances. If you are denied access to your PHI, you may request that the denial be reviewed.
• Request an amendment of PHI. If you feel that PHI we maintain about you is incomplete or incorrect, you may request that we amend it. To request an amendment, you must send a written request to privacy@glassesusa.com. You must include a reason that supports your request. If we deny your request for an amendment, we will provide you with a written explanation of why we denied it.
• Receive an accounting of disclosures of PHI. With the exception of certain disclosures, you have a right to receive a list of the disclosures we have made of your PHI, in the six years prior to the date of your request, to entities or individuals other than you. To request an accounting, you must submit a request in writing to privacy@glassesusa.com. Your request must specify a time period.
• Notification of a Breach. You have a right to be notified following a breach of your unsecured PHI, and we will notify you in accordance with applicable law.

To use our Platform, you must be over the age of sixteen (16). Therefore, we do not knowingly collect personal information from minors under the age of sixteen (16) and do not wish to do so. Any purchase of products through our Properties that is intended for a child under sixteen (16) 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 sixteen (16) are not using the Services. If we learn that we have collected personal information from a child under sixteen (16) 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 take great care in implementing and maintaining the security of our Platform. We employ industry standard procedures and policies to ensure the protection of personal information, and to prevent unauthorized use of any such information. Among other means we use Secure Socket Layer (SSL) technology, which creates an encrypted link between our web server and your browser, and provides a secured path of communication to ensure the information remains protected and private. Please note however, that regardless of the measures we take and the efforts we make, we cannot and do not guarantee the absolute protection and security of any personal information. From time to time, we may change the terms of this Privacy Policy. Changes will take effect once they are posted online and by accessing and/or using the Services after we make any such changes to this Privacy Policy, and you are deemed to have accepted such changes. If you do not agree with any of the amended terms, you must avoid any further use of the Properties and/or the Services provided thereon. 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 If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: customercare@glassesusa.com and we will make an effort to reply within a reasonable timeframe.

By contacting us, and accessing the Platform, you warrant and agree that you are free to do so, and that you are not providing us with information which violates any third party intellectual or privacy rights.

---

We use certain monitoring and tracking technologies, including ones offered by third party service providers to collect and process the personal information we specified above. These technologies are used in order to maintain, provide and improve our Platform on an ongoing basis, in order to provide a better experience to our Users and to provide our customers and potential customers with more relevant advertisements of our Services. For example, these technologies enable us to: (i) keep track of and apply our Customer's and Potential Customers’ Services and Website preferences and authenticated sessions, (ii) better secure our Services by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our Services, (iv) monitor and analyze our ads’ performance (v) create and monitor analytics relating to use of our Services, and (v) deliver to you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests.

Based on the foregoing, we’ve adopted this policy ("Cookie Policy") to explain how we use cookies and your related choices and options. In this policy we use the term "cookies" to refer to any applicable tracking technologies described herein. Cookies are a small text file that is stored on your device to help websites and mobile apps remember things about you. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. To learn more about cookies, visit http://www.allaboutcookies.org/

Pixel Tags (also known as web beacons or clear GIFs) are transparent images, iFrames, or JavaScript placed on a website or in marketing emails that are used to understand how you interact with such websites or emails.

Social Media Features, such as the Facebook "like" button, may collect your IP address and which page you are visiting on a website, and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features.

Single Sign-on allows you to log in to certain websites or mobile applications using sign-in services provided by third parties, such as Facebook or Google. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form. The cookies we use can be classified in one of the following categories:

Strictly Necessary cookies	We use these cookies to enable you to use our Platform’s features, such as enabling movement between pages and remembering information you enter on forms. Without these necessary cookies, services and functions on our Website will not be possible and our Website will not perform as it should.
Security cookies	We use these cookies to help identity and prevent security risks.
Authentication cookies	We use these cookies to help us show you the right information and settings when you are logged-in to our website.
Performance and Analytics cookies	We use these cookies to collect information about Users’ use of our Platform to help improve the way the Platform works. An example is counting the number of different people coming to our website or using a particular feature, rather than the total number of times the site or feature is used. Without this cookie, if you visited the website once each week for three weeks we would count you as three separate users. We would find it difficult to analyze how well our website was performing and improve it without these cookies.
Functionality and Preference cookies	We use these cookies to remember the choices you make such as which language you prefer and to provide you with personalized features. Furthermore, we use cookies to track the items in your shopping cart and may use that information to send you triggered email or text campaigns (e.g., sending you personalized text messages such as shopping cart reminders).
Targeting and Advertising cookies	We use these cookies to deliver you with ads when you browse the web that are more relevant to you and your interests, by remembering information such as what you looked at on our Platform and to track the performance of these ads.
Social Sharing cookies	We use these cookies to allow you to share content directly on the social network/sharing sites, like Facebook, Twitter or Google+ on which you have a user account. Examples would be if you wanted to "like" or "tweet" about a service or product advertised on our website

Strictly Necessary Cookies: Because these cookies are essential to operate our website, there is no option to opt out of these cookies.

Targeting and Advertising Cookies:

• You can opt out of interest-based targeting provided by participating ad servers through the Network Advertising Initiative at networkadvertising or the Digital Advertising Alliance at www.aboutads.info/
• You may be able to change your device settings (on your iPhone, iPad or Android) to control whether you see online interest-based ads
• You can opt out of some (but not all) of third party tracking technologies by following the instructions provided by the applicable third party service providers listed in the table below in their privacy policy.
• You can learn more about your options by visiting www.youradchoices.com or www.youradchoices.eu

Other Cookies:
You can follow the instructions provided by your website or mobile browser (usually located within the "Help", "Tools" or "Edit" facility) to modify your cookie settings.

You can opt out of some (but not all) of third party tracking technologies by following the instructions provided by the relevant third party service providers listed in the table below, in its privacy policy:

Cordial	This cookie allows us to improve experience by remembering preferences so that we can present the most relevant content. https://legal.cordial.com/privacy-policy/
Google Adwords - Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://policies.google.com/privacy?hl=en&gl=uk
Google Double Click - Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://policies.google.com/privacy?hl=en&gl=uk
Facebook - Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://www.facebook.com/about/privacy/
Twitter - Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://www.twitter.com/en/privacy
Outbrain - Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://www.outbrain.com/legal/
Taboola - Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://www.taboola.com/privacy-policy
Microsoft – Bing - Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://advertise.bingads.microsoft.com/en-us/resources/policies/microsoft-bing-ads-privacy-policy
TCA - Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive.
Pinterest - Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://policy.pinterest.com/en/privacy-policy
Vizury - Targeting and Advertising cookies	These cookies collect data for the purpose of interest-based advertising. http://web.vizury.com/website/cn/privacy-policy/
FullStory	These cookies allow us to obtain insight regarding the use on the website in order to improve User-Experience https://help.fullstory.com/11532-Security-Privacy-Performance
Impact Radius	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://impact.com/privacy-policy/
Criteo	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://www.criteo.com/privacy/
Dynamic Yield	This cookie helps us create a more personalized experience for our users, providing them with more relevant recommendations. https://www.dynamicyield.com/privacy-notice/
Mention Me	This cookie helps us measure performance to optimize user experience and prevent fraudulent use of the referral program. https://mention-me.com/help/privacy_policy_s

All of the Web browser cookies we use are stored on Users’ browser local memory. Therefore, by deleting such cookies from your local memory, we will not be able to associate any information we have about you, unless you login to our Platform as a registered user. We do not currently commit to responding to your browsers’ ‘Do Not Track’ signals with respect to our Platform, in part, because no common industry standard for ‘Do Not Track’ has been adopted by regulators, including no consistent standard of interpreting a user’s intent. We are committed to monitoring the developments around ‘Do Not Track’ and the implementation of a standard. We may update this Cookie Policy from time to time. We encourage you to periodically review this Cookie Policy to stay informed about our use of cookies, the information we collect via cookies, and any updates in relation thereto. If we make any changes to this Cookie Policy that significantly impact the way we use cookies, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Website. Your continued use of our Platform constitutes your agreement to this Cookie Policy and any updates. If you have any questions about our use of cookies, please contact us at customercare@glassesusa.com.