Privacy & SecurityCONTINUE SHOPPING
In accordance with applicable regulations, including without limitation the UK Data Protection Act 2018, the EU GDPR and other applicable data protection legislation, SmartBuyGlasses undertakes to comply with a number of important principles regarding the privacy and disclosure of your information.
Any questions about this Policy or more generally about SmartBuyGlasses’ use of personal data should be directed to the Data Privacy Officer, either via email at firstname.lastname@example.org or in writing to SmartBuyGlasses at 1/F, 12P Smithfield Road, Kennedy Town, Hong Kong.
We may need to update this Policy at any time and without notice and where we do this, we will ensure that such changes are appropriately published.
Motion Global Limited, a company organized under the laws of Hong Kong (together with its subsidiaries, affiliates, and/or related companies) (“SmartBuyGlasses”, “Company”, “our”, “we” or “us”), provides its customers and potential customers (“you”, “User”, “your”) with access to its websites located at www.smartbuyglasses.co.uk (“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”).
1. PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different categories of personal data about you through your interactions with us as follows:
• 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, preferred language, preferences etc.
• Marketing and Communications data including your preferences in receiving marketing from us and your communication preference.
• When you complete a survey.
• 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 or video through use of our “Try on” feature, or when you otherwise communicate with us via the Platform. One such feature is our proprietary “Lens 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.
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.
• Device Information: We collect information from and about the computers, phones, and other web-connected devices you use that integrate with our Platform (which includes our website, apps, order management system, warehouse management system, smartphone apps, social media accounts etc.) 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 Platform 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.
2. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you – unless you are resident in Hong Kong this will require an international transfer of data for which your consent is necessary.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• For processing your personal data in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by notifying us.
SmartBuyGlasses will not sell, distribute or lease personal data we hold to third parties, unless required to fulfil its contractual obligations with a customer or as required by law. Where SmartBuyGlasses does have to seek permission, we will name the relevant third party and any such permission shall be limited to that third party.
3. THE “VIRTUAL TRY-ON” FEATURE/BIO-METRIC DATA
You may choose to activate the Virtual Try-On feature from the website. The Virtual Try-On feature is powered by a third party service provider, Ditto. Ditto collects images of your face and asks for certain other information to run the feature. Ditto captures, collects, uses, and stores images of your face to create a facial reconstruction. That reconstruction allows us to show virtual eyewear on your face and provide you with customized information about eyewear.
Depending on the applicable laws that govern an end user who uses the Virtual Try On feature, a portion of the information collected through your usage of the “Virtual Try On” feature may be considered “bio-metric data”. If consent is required to collect, store and use the data that is collected, we will ask that you provide your agreement before using the feature.
We and Ditto only use the ”Virtual Try-On” related-data, including without limitation, the potential bio-metric data that is collected from you, to create the facial reconstruction and show you how you may look in the respective eyewear frames you have chosen to activate. We require Ditto to store your bio-metric data securely. We require that Ditto retain your bio-metric data for only so long as the initial purpose for collecting such bio-metric data has been satisfied or within three (3) years of your last interaction with us, whichever occurs first. We will not sell, lease, trade or otherwise profit from your bio-metric data, nor will any of our vendors who have access to such data be permitted to do so.
4. LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
When we use your personal data, the legal basis on which we rely to do so is as follows:
Purpose/Type of Activity Lawful basis for processing Account administration and relationship management Performance of a contract with you and consent to international transfer Internal record keeping (e.g., fulfilling orders you place) Performance of a contract with you and consent to international transfer Development and improvements of services Legitimate interests Internal management and management reporting Legitimate interests Improvements to our website Legitimate interests Direct marketing – current customers and potential via mail and telephone, or electronic marketing Consent Market Research Legitimate interests
5. SHARING WITH THIRD PARTIES; INTERNATIONAL TRANSFERS
Whenever we transfer your personal data internationally, where required by law we ensure a similar degree of protection is afforded to your personal data by ensuring at least one of the relevant mandated safeguards are implemented. In the case of transfers from the UK or EEA we will only transfer your personal data (i) to countries that have been deemed to provide an adequate level of protection for personal data by the relevant authority; (ii) in the manner allowed by the relevant law, including with Your consent; or (iii) where we use certain service providers, we may use specific contracts approved by the relevant authorities for such purposes (“Standard Contractual Clauses” or “Model Contracts”).
SmartBuyGlasses may also occasionally be required, either by law, government departments, agencies and regulators to collect, use and share certain types of personal data to comply with requirements and regulations. For the purposes as set out above, SmartBuyGlasses may also allow third parties to process personal data on behalf of SmartBuyGlasses to support our administration. Some third parties with whom we may need to share data may be based outside Your jurisdiction, so their processing of your personal data may also involve an international transfer of such data.
SmartBuyGlasses will hold Personal Information securely. Holding data securely is very important to us and we maintain reasonable physical, electronic and managerial procedures to keep all data secure. Please be advised that no security protocol can guarantee 100% security.
Only authorised employees and agents, contractors and sub-contractors, who provide data processing services for SmartBuyGlasses, are permitted access to the data. These individuals will only be allowed access to such data for the purposes identified within this Policy or for IT security and maintenance.
Where a third party is processing such data, SmartBuyGlasses will take steps to ensure that such third party provide commitments to ensure that the data processed is in accordance with applicable law. If a third party is processing such data and is located in a country which does not have data protection laws which require the necessary standards, we will always take appropriate additional steps to ensure that personal data is kept safe and secure by those processing such data on Our behalf.
We may use personal data to verify an individual’s identity to help prevent or detect fraud. These checks may involve information being disclosed to credit reference agencies, who may keep a record of that information. This is not a credit check and the customer’s credit rating will be unaffected.
7. RETENTION PERIOD
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
8.YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may have the right to:
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you wish to exercise any of these rights, please contact the Data Privacy Officer at email@example.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).
In the event you feel that SmartBuyGlasses has not held your personal information in an appropriate way, you may complain. We will endeavor to resolve any complaints received by the Privacy Officer promptly following receipt. We will keep in contact with you to ensure that you are kept informed of the progress and resolution of the investigation of your complaint. If you are not satisfied with the way in which your complaint has been dealt with, you have the right to lodge a complaint with your relevant data supervisory authority.
We will not discriminate against you for exercising your rights under this section.
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The Cookies We Use
• First-party cookies: These cookies are set by the website You’re visiting. And only that website can read them.
• Third-party cookies: These cookies are set by someone other than the owner of the website You’re visiting. Some SmartBuyGlasses web pages may also contain content from other sites like YouTube, which may set their own cookies. Also, if You share a link to a SmartBuyGlasses page, the service You share it on (for example, Facebook) may set a cookie on Your browser. We have no control over third-party cookies - You can turn them off, but not through us. This site uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how You use the site and ways that we can improve Your experience. These cookies may track things such as how long You spend on the site and the pages that You visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.
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• Strictly necessary cookies: These cookies let You use all the different parts of SmartBuyGlasses website. Without them, services that You’ve asked for can’t be provided. Some examples of how we use these cookies are: signing in to Your account, remembering text You have entered into a form, flash settings, etc.
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