ZENNI OPTICAL VISON-TEST VIRTUAL REALITY APP PRIVACY POLICY
Last Updated: October 22, 2024
Zenni Optical, Inc. (“Zenni,” “Company,” “us,” “we,” or “our”) respects the privacy of individuals who provide us with personal information by visiting our website, using our apps, Services or purchasing our products. This Privacy Policy explains how we collect, use, share your personal information, the rights and choices you may have with respect to your personal information, and how to assert those rights.
By accessing, visiting or using our Services, you acknowledge this Privacy Policy and agree to our Terms of Use. If you are not comfortable with any part of this Policy or do not agree with the Terms of Use, please immediately discontinue access or use of our Services.
We may make changes to this Privacy Policy from time to time. Please review the “Last Updated” legend at the top of this page to determine when this Privacy Policy was last updated. Any changes to this Privacy Policy will become effective on the “Last Updated” date indicated above. If we make material changes to the Privacy Policy, then we will notify users by posting a notice on our website and/or via email prior to such use or by other means as required by law.
We may also provide “just-in-time” disclosure or additional information about our information collection, use, and sharing practices of specific Services. These notices may supplement or clarify our privacy practices or provide you with additional choices about how we process your personal information.
This Privacy Policy applies to all personal information that we collect during any written, electronic, or oral communications when you access and interact with our vision-test virtual reality app available on Meta Platforms (the “Services”).
We collect certain personal information when you use our Services. Personal information is typically data that identifies an individual or relates to an identifiable individual. The definition of personal information (used interchangeably with “personal data”) depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Policy. The personal information that we collect depends on your interactions with us, and the choices you make.
Information You Voluntarily Provide. The types of personal information that we or third-party service providers who assist us (in providing, maintaining, and operating our Services) may collect from you include:
Information We Automatically Collect. To the extent permitted under the applicable law, we may automatically collect certain type of personal information about you when you use the or interact with the Services.
We may automatically collect information from you when you use the Services using “cookies” and other similar technologies, such as web beacons (“Tracking Technologies”), to automatically collect information about you when you use the Services and to personalize your experience with our Services. We and third-party businesses on our behalf, may use Tracking Technologies to help us customize your experience and better manage content on our Services.
Cookies are small amounts of data that are stored within your computer’s Internet browser and that are accessed and recorded by the websites that you visit so that they can recognize the same browser navigating online at a later time. Information that may be collected by cookies when you use the Services may include, without limitation: the date and time of your visit to the virtual reality app; the amount of time you spend using the virtual reality app; the IP address used to connect to the Internet; and/or your connection information such as type and version, operating system and platform.
Generally, we use first-party and third-party cookies for the following purposes: to make our Services function properly; to provide a secure browsing experience during your use of our Services; to collect passive information about your use of our Services; to measure how you interact with our marketing campaigns; to help us improve our Services; and to remember your preferences for your convenience.
We may place cookies from third-party service providers who may use information about your visits to other websites to target advertisements for products and services available from us. We do not control the types of information collected and stored by these third-party cookies. You should check the third-party's website for more information on how they use cookies. We use the following types of cookies on our Services:
We use your personal information for the following business and commercial purposes, unless restricted by applicable law:
We use personal information we gather through the Services to provide you with our Services that you request, such as creating and managing user accounts and processing your vision test. If you choose to use our Virtual Try-On and/or PD Measurement services, we use the photographs, videos, and or facial scans you provide through the Services to create a digital reconstruction of your face. With this reconstruction, we can show you how a pair of glasses would look on your face with the Virtual Try-On tool. Similarly, with the PD Measurement tool, we can determine your pupillary distance, which is needed to produce prescription eyeglass lenses.
We may use your personal information to communicate with you. We may send you administrative or account-related information to keep you updated about your account and the Services. Such communications may include information about privacy policy and terms updates, security updates, tips or other relevant transaction-related information. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to your account or the Services. Additionally, when placing on order for glasses through the Services, you will have the ability to opt-in to receive “Renewal Reminders” from us. If you opt-in to receive Renewal Reminders, we will use the email address you have provided to us to send you reminders that your prescription (Rx) may require renewal.
We collect any information that you provide to us when you contact us. Without your personal information, we cannot respond to you or ensure your continued use and satisfaction of the Services.
If you have voluntarily provided your email address, phone number or other electronic addresses to us when subscribing to our marketing communications, we may email you about products, services, and promotions that we believe may be of interest to you. When you no longer wish to receive these marketing messages from us, you can opt out at any time by following the instructions contained in each email you receive from us or contacting us via the methods specified in the “How to Contact Us” section below.
We may process your personal information and derive analytical and statistical data to better understand the way you use and interact with our Services. For instance, analyzing where, on which types of devices and how our Services are used, how many visitors we receive, and where they navigate to in the virtual reality app may help us improve our existing Services and to build new Services. Please see our Cookies and Other Similar Tracking Technologies section for more information.
We may process your information to personalize your experience. By personalization, we enable you to interact with our Services more easily across platforms and devices.
We may process any information regarding your account and your use of our Services as is necessary in the context of corporate acquisitions, mergers or other corporate transactions.
When you access or use our Services, you are bound to our Terms. We may process your personal information when actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services. We may also process your personal information to investigate, prevent or mitigate violations of our internal terms, agreements or policies; and enforce our agreements with third parties.
We may process your personal information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information.
Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, or as necessary to manage risk as required under applicable law, or to respond to requests by judicial process or governmental agencies.
From time to time, we may offer you an opportunity to participate in promotions and/or sweepstakes (collectively, “Promotions”) via the Services or through a third-party platform. If you choose to participate in a Promotion, we will collect and store the personal information you provide in connection with your participation in the Promotion, including, but not limited to, your name, email address, , and/or phone number. We may provide “just-in-time” disclosure or additional information about our information collection, use and sharing practices of specific Promotions. Information we collect in connection with a Promotion will be used to administer the Promotion, such as by notifying winners and distributing prizes. As permitted by applicable law, your personal information may also be used by Zenni or the Promotion sponsor for marketing purposes. Acceptance of a prize may require you (unless prohibited by law) to allow us to post publicly some of your information via the Services, such as on a winner's page.
For any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the services or other related services requested, with your permission or upon your direction.
We may disclose your personal information as described below:
We may share some or all of your personal information with our parent company, subsidiaries and corporate affiliates, joint ventures, or other companies under common control with us. If you opt-in to receive marketing communications from third parties, we may permit these entities to use your information for their own marketing purposes. If you would like us to stop providing your information to our affiliates for their own marketing purposes, you may opt-out by emailing us at privacy@zennioptical.com.
We may disclose your personal information to our contractors, affiliates, distributors and suppliers (“Service Providers”) who provide certain services to us or on our behalf, such as fulfilling orders you place through the Services, processing payments, operating and supporting the Services, including the Zenni Frame Fit™ service, analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the information needed to perform these limited functions on our behalf.
If you choose to use our Virtual Try-On and/or PD Measurement services, your photographs, videos, and/or facial scans will be shared with Luna, whose technology powers these services. We and Luna will only use the data you share with us as part of the Virtual Try-On and/or PD Measurement services to show you how you may look in eyewear frames or to measure your pupillary distance, respectively. We require Luna to store your information for no longer than necessary as to provide you these services and at most, no more than three years. We and Luna will not sell the information you share with us when using the Virtual Try-On and PD Measurement services. For more information about the personal information Luna collects and processes to help Zenni provide the Virtual Try-On and PD Measurement services, please see Luna’s Privacy Policy, available at: https://luna.io/trust/privacy/.
We may disclose personal information to government authorities or third parties if: (a) required to do so by law, or in response to law enforcement requests and legal processes, such as a subpoena or court order; (b) comply with requests from auditors, examiners or other regulators; (c) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or (c) we believe that you have abused the Services by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.
In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any personal information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign personal information and other information we have collected from users of the Services to buyers, service providers, advisors, potential transactional partners or other third parties in connection with the advisors, potential transactional partners or other third parties of a corporate transaction. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Privacy Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
If you affirmatively opt-in to receive marketing communications from third parties, we may, from time to time, share personal information you provide to us with selected third-party marketing partners that we believe offer products or services that may be of interest to you. If you would like us to stop providing your information to our third-party marketing partners, you may opt-out by emailing us at privacy@zennioptical.com To learn more about your choices and rights, please review the “Your Choices and Rights” section below.
We may share your personal information with other companies if you give us permission or direct us to share your information.
The Services may include links to other third party websites and content from third party businesses. Zenni does not have access to or control over these third parties or the cookies, web beacons or other technology that these third parties may use. We are not responsible for the privacy practices of these third parties or the content on any third-party website. You are encouraged to review the privacy policies of the different websites you visit and of the advertisers whose ads you may choose to click while on our Services (see section 2 above for additional information about online advertising).
A. Your Choices
We offer you certain choices about how we communicate with you and manage what personal information we collect from you.
All users may request deletion of any collected or stored user data in the virtual reality app by emailing customer service at service@zennioptical.com
If you have created a user account through the Services, you will have the ability to access, update and correct the personal information you have provided in connection with your account by logging into your account through the Services.
We offer you certain choices about how we communicate with you. To update your preferences, limit the communications you receive from us, please contact us as specified in the “How to Contact Us” section at the end of this Privacy Policy. Where provided by law, you may withdraw your consent previously provided to us, and we will apply your preferences going forward. You can also choose not to receive marketing communications from us by clicking on the unsubscribe link in our marketing content.
You have the right to decide whether to accept cookies. If you do not want us to deploy cookies in your browser, you may exercise your preference by clicking “Your Privacy Rights” in the footer, by clicking here or by modifying your web browser setting to refuse some or all cookies or to notify you and ask for your permission when a website tries to set a cookie. If you want to learn how to modify your browser settings, please use the “Help,” “Tools” or “Edit” menu in your browser or review the instructions provided by the following browsers: Microsoft Edge, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile; and Android browser. If you block or delete technical and/or function cookies used by our Services, the Services may become impossible to browse, certain services or functions of the Services may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Services.
Analytics. We may use third-party service providers to monitor and analyze the use of our Services, such as Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports website traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.
Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members. To opt out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1. Residents of the European Union may opt-out of online behavioral advertising served by the European Interactive Digital Advertising Alliance’s participating member organizations by visiting https://www.youronlinechoices.eu/.
You may also access industry-provided opt-out tools, although they are not tailored to our Services. For instance, to opt-out of data collection by the Digital Advertising Alliance’s participating member companies for interest-based advertising across mobile applications, download the DAA’s App Choices mobile application opt-out offering at https://youradchoices.com/appchoices.
B. Your Privacy Rights
Depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your personal information. If any of the rights listed below are not provided to you under the law that governs the processing of your personal information, we have absolute discretion in providing you with those rights. Please refer to the “What Rights Apply” section to determine the rights you have in the jurisdiction you reside.
Please note, your rights in relation to your personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (i) when denial of the request is required or authorized by law; (ii) when granting the request would have a negative impact on another's privacy; (iii) to protect our rights and properties; (iv) where the request is frivolous or vexatious, or for other reasons.
You may have the right to obtain a copy, or a list of categories of the personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information.
You may have the right to correct any of your personal information in our records and systems. You may request us to rectify, correct or update any of your personal information held by us that is inaccurate.
Under certain circumstances, you may have the right to request that we delete the personal information that we hold about you. This right is not absolute, and we may refuse your right to delete if it is reasonably necessary for us to provide a service requested by you; to perform a contract between us; to maintain functionality and ensure security of our systems; to enable solely expected internal uses of your personal information; to exercise a right provided by law; to comply with a legal obligation, or if there are compelling legitimate grounds for keeping your personal information.
Under certain circumstances, you may have the right to receive personal information we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another entity.
You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your privacy rights.
You may have the right not to be subject to a decision that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement) which significantly impacts your rights. No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.
We may seek to rely on your consent in order to process certain personal information. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
You may have the right to request that we restrict our processing of your personal information in certain circumstance. For instance, this right is available if you contest the accuracy of the personal information, or you objected to our processing.
You may have the right to object to our processing of your personal information at any time and as permitted by applicable law if we process your personal information on the legal bases of: consent, or legitimate interests. However, we may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
You may have the right to appeal if we refuse to take action on your rights request. Instructions on how to appeal will be provided to you upon such a denial, but in any event, such instructions will be substantially similar to those provided below for submitting requests.
To determine which rights you have, please refer to the table below that references the rights as described above. U.S. States not listed either do not have a law providing such rights, or it does not apply to our operations.
Jurisdiction | Applicable Rights |
California Residents | (a) Right to Know/Access; (b) Right to Correct/Rectification; (c) Right to Delete/Erasure; (d) Right to Portability; (e) Right Against Discrimination; and (f) Right to Opt-Out of Automated Decision-making or Profiling (upon issuance of regulations by the California Privacy Protection Agency) |
Virginia, Colorado & Connecticut, Oregon & Texas Residents | (a) Right to Know/Access; (b) Right to Correct/Rectification; (c) Right to Delete/Erasure; (d) Right to Portability; (e) Right to Opt-Out of Automated Decision-making or Profiling; and (j) Right to Appeal; and (g) Right Against Discrimination |
Utah Residents | (a) Right to Know/ Access; (c) Right to Delete/Erase; (d) Right to Portability; and (e) Right Against Discrimination |
European Economic Area, United Kingdom and Switzerland (for individuals located in these jurisdictions when their personal information is collected) | (a) Right to Know/Access; (b) Right to Correct/Rectification; (c) Right to Delete/Erasure; (d) Right to Portability; (f) Right to Opt-Out of Automated Decision-making or Profiling; (g) Right Not to Provide Consent or to Withdraw Consent; (h) Right to Restriction; and (i) Right to Object to Processing |
Submitting a Request to Exercise Your Privacy Rights
To assert your privacy rights noted above, please email privacy@zennioptical.com and indicate which rights you would like to exercise. Please note California and Texas residents may do so up to twice per year per customer, and Colorado and Oregon residents may do so once per year per customer. We may charge a reasonable fee for multiple requests in the same 12-month period, as permitted by law.
To protect your privacy, we must be able to verify your identity to confirm that the request came from you before we can process your request to exercise any of the privacy rights that you may be entitled to under the applicable law. We may contact you by phone or e-mail to verify your request. Depending on your request, we will ask for information such as your name, an e-mail address that you have used with Zenni, or a phone number you have used with Zenni. For certain requests, we may also ask you to provide details about the most recent purchase you made online.
Residents of California, Colorado, and Connecticut may designate an authorized agent to submit a request on your behalf to access or delete your personal information. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.
C. Your Opt-Out Rights
If you reside in California, Colorado, Connecticut, Virginia, Oregon or Texas you may have the right to opt-out of certain types of processing for your personal information.
Right to Opt Out of Sale. You may have the right to opt-out of the sale of your personal information. We generally do not sell your personal information for profit, but like many businesses, we use cookies, pixels, and similar technology , and we share certain personal information, such as your IP address or device identifiers, to third-party advertisers in order to improve your user experience and to optimize our marketing activities. Under the broad definition of “sell” contained in some jurisdiction’s privacy laws, this could be considered a sale.
Right to Opt Out of Targeted Advertising. You may have the right to opt-out of the sharing of your personal information to third parties for behavioral or cross-contextual advertising purposes. Like many websites, we use cookies, pixels, and similar technology, and we share certain information, such as your IP address or device identifiers, to certain third-party advertisers in order to improve your user experience and to optimize our marketing activities. You have the right to direct us not to share or use your personal information for targeted advertising purposes.
To exercise your right to opt-out of sales and targeted advertising, please click the “Your Privacy Rights” link in the website footer and switch off the toggle for “Opt Out of Sale/Sharing/Targeted Advertising.” Please note that you may still receive generalized ads after opting out of targeted advertising.
If you are a resident of California or Colorado, you may also opt-out of sharing and sales by using an opt-out preference signal. The Global Privacy Control signal is currently the only opt-out preference signal we can recognize. You can visit the Global Privacy Control official site at https://globalprivacycontrol.org/#about to learn how to configure your device to send such signals. We will honor and process the opt-out preference signal in a frictionless manner. Please note that the opt-out choice will only apply to your use of our Services through the current browser or device you are using and only so long as that browser’s cookies are not erased. You will need to submit a separate opt-out of sharing request on each device and browser you use to completely opt-out using this method. Please note that you may still receive generalized ads after opting out of targeted advertising.
Residents of Oregon may designate an authorized agent to submit a request to opt-out of sale and/or targeted advertising.
Our Services are not intended for children under age 16. We do not knowingly collect or distribute personal information that we collect directly from children under the age of 16. When parents or legal guardians of children under 16 place orders for children’s glasses through our Services, we may collect prescription information for children under the age of 16, and other information as necessary to deliver Zenni products. We will use this prescription information and related information collected in the course of fulfilling that order only for fulfilling the applicable order, and only within the limits permitted by applicable law.
If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us via the method identified in the “How to Contact Us” section below. If we become aware that a child under 16 has provided us with personal information, we will terminate the user’s access to our Service and take steps to delete such information from our systems, unless we have a legal obligation to keep it.
We will retain your information for as long as your account is active, as needed to provide you Services or for other purposes stated in this Policy. We will cease to retain your personal information or remove the means by which the personal information can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal information was collected and is no longer necessary for legal or business purposes. If you wish to cancel your account or request that we no longer use your information to provide you services, we may still retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We implement security measures intended to protect against the loss, misuse and alteration of the personal information under our control. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the internet. Please remember that you play a valuable part in security as well. If you feel that the security of any account you might have with us has been compromised, you should contact us immediately as described in the “How to Contact Us” section.
We are an online retailer of prescription glasses, based in the United States. Our business operates on a global scale. When you access or submit information to us, your personal information may be transferred to, processed, maintained, and used on computers, servers and systems located where the data protection laws may not be as protective as those in your jurisdiction. In addition, we may transfer your personal information to our service providers located in China to fulfill orders you place through the Services. We will take appropriate contractual or other steps to protect the relevant personal information in accordance with applicable laws.
We offer our customers loyalty programs (Zenni Loyalty Rewards Program, Military, First Responder & Medical or Nurse Personnel, Student and Teacher Discount Programs, and Refer a Friend Program) that provides certain perks, such as rewards and special promotions. We may also provide other programs, such as sweepstakes, contests, newsletters, or other similar promotional campaigns (collectively, the “Programs”). When you sign up for one of our Programs, we will ask you to provide your name and contact information (such as email address and/or telephone number). Because our Programs involve the collection of personal information, they might be interpreted as a “financial incentive” program under California law. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the Program.
You may withdraw from participating in a Program at any time by contacting us using the designated method set forth in the applicable Program terms. Visit the terms and conditions page of each Program to view full details, including how to join. To learn more, please check out our FAQ page for the loyalty programs, and the Terms and Conditions for each Program, available through the navigation bar on Terms and Conditions | Zenni Optical.
If you are a California resident, this section applies to you in addition to the rest of this Privacy Policy. The California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”) requires us to disclose the following additional information related to our privacy practices.
Categories of Personal Information Collected, Used, and Disclosed
In the preceding 12 months, depending how you interact with our Services, we may have collect the following categories of personal information (as defined under Cal. Civ. Code §1798.140(v)(1)):
We generally do not collect protected classifications about our users, biometric information, professional or employment-related information, or education-related information. For more information about the Personal Information we collect and how we collect it, please refer to Section 2 above.
Purposes for Collecting and Using Categories of Personal Information
We collect and use your personal information for the following business purposes:
For more information about the purpose of collecting and using the categories of personal information listed above, please refer to Section 4 above.
Sale or Share of Personal Information
We may share or sell your identifiers, device information, demographic information and geolocation to advertising networks, and our business partners. To exercise your right to opt-out of sales and targeted advertising, please click the “Your Privacy Rights” link in the website footer or here, and switch off the toggle for “Opt Out of Sale/Sharing/Targeted Advertising.” Please note that you may still receive generalized ads after opting out of targeted advertising.
You may also opt-out of sharing and sales by using an opt-out preference signal. The Global Privacy Control signal is currently the only opt-out preference signal we can recognize. You can visit the Global Privacy Control official site at https://globalprivacycontrol.org/#about to learn how to configure your device to send such signals.
Zenni does not knowingly sell or share (for cross-context behavioral advertising) the personal information of consumers under 16 years of age.
Retention of Personal Information
We retain your information for as long as your account is active, as needed to provide you Services or for other purposes stated in this Policy, or as required or permitted by applicable law. For more information about the criteria for retaining personal information listed above, please refer to Section 9 above.
Your Right to Limit Use of Sensitive Information
If you are a California resident, to the extent your sensitive personal information (as that term is defined under the CCPA) is used to infer characteristic about you, you have the right to direct us to stop such processing of your sensitive personal information for such purposes. We may process your precise geolocation for notification delivery purposes from time to time, and you may limit this type of processing by adjusting Zenni App’s access to your location data from the mobile device level.
Shine the Light
In addition to the CCPA, California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California residents asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if a California customer has exercised an option to opt out of such information sharing. We have such a policy. If you want to opt out of any such sharing of your information, please contact us using the information below.
Do Not Track
Your browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. However, since uniform standards for “DNT" signals have not been adopted, we do not disable tracking technology that may be active Servicesin response to any “do not track” requests that we receive from your browser.
This Section provides additional information to individuals located in Canada at the time their personal information is collected by Zenni. You may request details about our privacy practices, access or correct your personal information, or make a complaint by contacting our privacy officer in writing at: Zenni Optical, Inc., 448 Ignacio Boulevard, Suite 332, Novato, CA 94949 USA, or at privacy@zennioptical.com.
If you are not satisfied with our response to your inquiry, you may contact the Office of the Privacy Commissioner of Canada: 1-800-282-1376 (toll-free) or priv.gc.ca
This section only applies to individuals using or accessing our Services while located in the European Economic Area (“EEA”), the United Kingdom, and Switzerland (collectively, the “European Countries”) at the time of data collection. Pursuant to the European Union’s General Data Protection Regulation, and the UK General Data Protection Regulation (collectively, the “GDPR”), for the sake of clarity, references to personal information in this Policy concern personal data in the sense of the GDPR.
We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in European Countries.
The controller for the processing described in this Privacy Policy is: Zenni Optical, Inc.,448 Ignacio Blvd, #332, Novato, CA 94949, and you can contact Zenni’s privacy officer at privacy@zennioptical.com.
You may direct questions or otherwise exercise your rights in respect of your personal data by contacting our Data Protection Representative in the European Countries, DataRep, by sending an email to datarequest@datarep.com, quoting “Zenni Optical Inc.” in the subject line; or by submitting online webform at www.datarep.com/data-request.
Legal Bases for Processing Your Personal Information
The legal bases under the GDPR for our processing of personal data of individuals, which are located in European Countries at the time of collection, for each of the processing activities described above in Sections 3 and 4 is identified in the chart below.
Processing Activity | Legal Bases for Processing |
Section 3(i) To Ensure the Security of the Services Section 3(j) To Maintain Legal and Regulatory Compliance Section 4(c) Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies | Based on our legal obligations. Article 6(1) lit.(c) GDPR. |
Section 3(a) To Fulfill Orders and To Provide Our Services Section 3(b) To Provide You Services-Related Communications Section 3(c) To Provide Customer Support and Respond to Requests Section 3(h) To Enforce Compliance with Our Terms, Agreements and Policies Section 4(a) Within Our Corporate Organization Section 4(b) With Our Service Providers Section 4(e) With Marketing Partners | Based on our contract with you or to take steps at your request prior to entering a contract. Article 6(1) lit.(b) GDPR. |
Section 3(e) To Research and Develop Our Services Section 3(f) To Personalize Your Experience Section 3(g) To Facilitate Corporate Acquisitions, Mergers and Transactions Section 4(d) During Business Transfers; Bankruptcy | Based on our legitimate interest to operate our business and not overridden by your data protection interests or fundamental rights and freedom. Article 6(1) lit.(f) GDPR. |
Section 3(d) To Provide Marketing Communication Section 3(k) With Your Consent Section 4(f) With Your Consent | Based on your consent. Article 6(1) lit.(a) GDPR. |
Right to Lodge a Complaint to Your Local Data Protection Authority
If you reside in the European Countries you may have the right to lodge a complaint with your national data protection authority or equivalent regulatory body. You can find details of EEA Supervisory Authorities here: https://edpb.europa.eu/about-edpb/board/members_en. The Supervisory Authority in the UK is the Information Commissioner’s Office (ICO).
International Transfer of Your Personal Information
We rely primarily on the European Commission’s Standard Contractual Clauses to facilitate the international and onward transfer of personal information collected in the European Economic Area (“EEA”), the United Kingdom and Switzerland (collectively “European Personal Information”), to the extent the businesses receiving he European Personal Information are located in a country that the European Countries consider to not provide an adequate level of data protection. We may also rely on an adequacy decision of the relevant regulatory body confirming an adequate level of data protection in the jurisdiction of the party receiving the information, or derogations in specific situations.
If you have any questions or complaints regarding this Privacy Policy, please contact us by sending an email to privacy@zennioptical.com. We will investigate your question, respond to your inquiry, and attempt to resolve any concerns regarding your privacy question. If we need, or are required, to contact you concerning any event that involves your personal information we may do so by e-mail, telephone, or mail. For individuals in Canada, please see Section 14 for additional contact information. For individual in the European Countries, please see Section 15 for additional contact information.