SmartBuyGlasses Privacy Policy

SmartBuyGlasses Optical Limited, together with our subsidiaries, affiliates, and, related companies, (“SmartBuyGlasses”, “our”, “we” or “us”), is an optical wear e-commerce company offering one of the world’s largest ranges of designer glasses, paired with innovative technological solutions to enable the purchasing of personalised optical wear online.

This Privacy Policy describes our practices regarding the collection, storage, use, and disclosure of personal data relating to identified or identifiable individuals (“personal data” or “personal information”) who engage or otherwise interact with us (“you” or “your”), including when visiting or using our websites and their associated features (including at www.smartbuyglasses.ca), our mobile application, and any other local domain, website, webpage, e-mail, text message , online ad or other sales and marketing channel under our control (collectively - the “Services").

We respect your privacy rights, and we are committed to protecting the personal information that is shared with, or otherwise made available to us. 

Specifically, this Privacy Policy describes our practices regarding:

1. Data Collection
2. Data Uses
3. Data Location and Retention
4. Data Disclosure
5. Cookies & Tracking Technologies
6. Communications
7. Data Security
8. Your Rights
9. Additional Notice & Contact Details

Please read this Privacy Policy and associated Terms and Conditions carefully before engaging with us in any capacity and make sure that you fully understand and agree. You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined in Section 4 below), please refrain from accessing, using or registering to our Services or engaging with us in any other manner.  

1. Data Collection and Processing

• Usage data: When you interact with our Services, we may process your personal data including IP addresses and approximate location based upon such IP addresses, digital identifiers, device data (like type, OS, device id, browser version, locale and language settings used), user agent, activity logs, session recordings, the cookies and pixels installed or utilised on your device (see Section 5) and inferred or presumed data on or generated from your use of the Services. 

• Customer data: When you register for a membership with us via the Services, complete an order with us, or otherwise engage with us via the Services, including through the features we offer (for example the Lens Scanner, Pupillary Distance tool, or Virtual Try-On features), we may process personal data, including contact and profile information (name, email, phone number), eyeglass prescription (where this is provided to us by way of an optical script, we collect information contained in that script, for example your optician’s details and any other personal data contained therein), Pupillary Distance, physical address, gender, birth date, account activity (including payment method and details, transaction history, purchasing and product preferences and patterns), military or veteran status (when applying for the military discount), government-issued identity numbers, for example, TaxID (where relevant for customs purposes) and health ID (if included in your physical optical prescription), details about your insurance policy, including insurance provider (where you provide these to us to facilitate an insurance claim), and any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement.

• Feature data: Some of the features we offer via the Services, such as the Lens Scanner or Virtual Try-On (“VTO”) feature process additional types of personal data.

• When using the Lens Scanner, we may process personal data including optical data, such as glasses parameters, lens analysis, lens power, pupillary distance, and optical prescription.
• When using the VTO feature, we may process data including a capture of your face measurements and scan of your facial geometry. The VTO technology operates on an estimation of a standard 3D facial geometry, based on the image you submit via the Services (mathematic points that can be found on every face) to create a facial reconstruction and show you how you may look in the respective eyewear frames you have chosen to activate, in real time. Your image is immediately deleted once this reconstruction has occurred.
• When using the Pupillary Distance Tool, we may process personal data including pupillary distance.

• Business contact data: If you engage with us in your professional capacity, provide a professional service to us, or explore potential business opportunities or partnerships with us, we may process the following types of data: name, email address, phone number, position, workplace, contractual and financial documents, and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement.

We collect and generate this information:

• Directly from you when you interact with our Services, complete our online form(s), register for an account with us, update your account details, communicate with our customer or support services, engage with our opticians, interact with us, including through social media channels, instant messaging apps or the chat feature on our Services, provide feedback, survey responses or other testimonials, register to our mailing list, or communicate with us in any other manner.
• Automatically, including through the use of analytics tools. We may also collect aggregated or technical data generated when you use our Services, relating to how you use them, so we can learn how users use our Services and to improve the Services and users’ experience.
• From third parties, including publicly available sources, our Service Providers (defined in Section 4 below), for example, optical solutions technology providers, marketing and sales providers, data enrichment services, social media platforms and sites and analytics providers that integrate their services with ours or provide us access to their services, payment processors; or via the friends referrals program from our members (as detailed in Section 6 below), and other business initiatives.

For the purposes of the California Consumer Privacy Act ("CCPA"), in the last 12 months, we have collected the following categories of personal information, as defined in the CCPA: Identifiers; Geolocation data; Customer records information; Characteristics of protected classifications; Commercial information; Internet or other electronic network activity information; Audio, electronic, visual, or similar information; Professional or employment related information; Inferences; and Sensitive Personal Information (as described above).

2. Data Uses

We use personal data for the following purposes and in reliance on the lawful bases noted in the chart below:

If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to be processed by or via the Services, or due to nature of such processing), your acceptance of our Terms and Conditions (and/or the terms that govern our relationship with you) and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed herein. If you wish to revoke such consent, please contact us at

3. Data Location and Retention

Data Location: We and/or our authorised Service Providers maintain, store and process personal data in Hong Kong, the United States, European Union, Australia and in other locations as reasonably necessary for the proper delivery and performance of our Services, or as may be required by law. Since we operate globally and may use service providers worldwide, we may transfer your personal data outside your country of residence. 

While privacy laws may vary between jurisdictions, SmartBuyGlasses is committed to protecting personal data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such personal data is transferred.

For data transfers from the European Economic Area, the UK and Switzerland, we will transfer your personal data only to such countries approved by the European Commission, FDPIC and UK Information Commissioner’s Office respectively, as providing adequate level of data protection, or enter into Standard Contractual Clauses as approved by the relevant data protection authority. You can obtain a copy of these clauses by contacting us as indicated in Section 9 below.

Data Retention: Generally, we will retain your personal data for as long as it is reasonably necessary for us to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our contractual terms and data retention policy.

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at privacy@smartbuyglasses.com.

4. Data disclosure

We disclose personal data in the following ways:

• Service Providers: We engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers may include commercial software providers, hosting and server co-location services, communications and content delivery networks, data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, content transcription and analysis services, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, website chat services, optical solution technology providers, delivery or logistics providers, our legal, financial and compliance advisors, and our contractors (for example, our opticians) (collectively, “Service Providers“). Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.

• Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data in response to a legal request, such as a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interest, including the security or integrity of our products and Services.

• Event Partners: If you register for any event that we host, organise or sponsor, then with your permission we may share your registration details with others, including the hosts, organisers, speakers, service providers, and sponsors of that event, so that they may contact you with relevant information and offers, or to fulfil any promotions related to that event.

• Protecting Rights and Safety: We may share your personal data with others, if we believe in good faith that this will help protect the rights, property or personal safety of SmartBuyGlasses, any of our Services’ visitors, customers, business or professional contacts, or any members of the general public.

• Affiliated Companies: We may share personal data internally with our affiliated companies, for the purposes described in this Privacy Policy. In addition, should SmartBuyGlasses or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal data may be shared with the parties involved in such event.

• Additional Disclosure: SmartBuyGlasses may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. Additionally, we may transfer, disclose or otherwise use non-personal data at our sole discretion and without the need for further approval.

For the purposes of the CCPA, in the past 12 months, we have disclosed: Identifiers; Geolocation data; Customer records information; Characteristics of protected classifications; Commercial information; Internet or other electronic network activity information; Audio, electronic, visual, or similar information; Professional or employment related information; Inferences; and Sensitive Personal Information to the parties listed above. We did so in pursuit of the business and commercial purposes described in Section 2 above. We do not use or disclose sensitive personal information outside of purposes permitted under the CCPA.

5. Cookies & Tracking Technologies

Cookies: Our Services utilise “cookies”, anonymous identifiers, pixels, container tags, and other technologies in order for us to provide our Services and ensure that they perform properly, to analyse our performance and marketing activities, and to personalise your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data (such as an IP address) previously indicated by a visitor to our Services. To learn more about our practices concerning cookies and tracking, including your ability to opt out of Targeted Advertising under relevant US State laws, or the sale or sharing of your personal information (as such concepts are defined in the CCPA), please review our Cookie Policy below.

Google Analytics: We use Google Analytics to collect information about the use of our Services. Google Analytics collects information such as how often you visit the Services, which pages you visited when doing so, and which other sites you used prior to coming to our Services. We do not merge the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Services is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can learn more about how Google collects and processes data specifically in connection with Google Analytics here. Further information about your option to opt-out of these analytics services is available here.

6. Communications

Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us, including by e-mail, SMS and mobile notifications) of changes or updates to our Services, billing issues, password reset notices, etc. Please note that you will not be able to opt out of receiving certain communications which are integral to the operation and use of our Services (like password resets, invoices or order updates).

Promotional Communications: We may also notify you about new features, additional offerings, better ways to use the Services, events and special opportunities, or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., phone, SMS, mobile notifications, or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify SmartBuyGlasses at any time by sending an e-mail to privacy@smartbuyglasses.com, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

Friends’ Referral: We may contact you with special offers if your friend provides us with your contact information and asks us to contact you for this purpose.

7. Data Security

SmartBuyGlasses and its Service Providers implement systems, applications, and procedures to secure your personal data, to minimise the risks of theft, damage, loss of information, or unauthorised access or use of information. These measures provide sound industry-standard security. However, please be aware that regardless of any security measures used or implemented, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties. 

8. Your Rights

Individuals have rights concerning their personal data. if you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (“GDPR”), and US State Privacy laws, including the CCPA, as amended from time to time, please contact us by e-mail at: privacy@smartbuyglasses.com.

Such rights may include (each to the extent available to you under the laws which apply to you) the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with SmartBuyGlasses, or to restrict or object to such personal data’s processing (including the right to direct us not to sell or share your personal data to third parties now or in the future, or the right to opt-out of processing personal data for the purposes of targeted advertising, as described below), or to port such personal data, or the right to equal services and prices (e.g., freedom from discrimination).

To the extent applicable to you, you may also designate an authorised agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. When you or an authorised agent ask us to exercise any of your rights, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. We may not be able to fulfil your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we collected the personal data. We may then request additional information for legal purposes (e.g., as proof of the identity of the person submitting the request, or proof of request fulfilment).

We may redact from the data which we make available to you, any personal data or confidential information related to others. 

To the extent applicable to you, you may also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, or relevant US state Attorney General, as applicable.

9. Additional Notices and Contact Details

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. We will make reasonable efforts to post a clear notice on our Services and/or we send you an email (to the extent that you provided us with your email address) regarding the change if we believe any substantial changes are involved. Such changes will take effect four (4) days after the notice is posted on the Services or sent via email, whichever is earlier. After such notice period, all amendments to this Privacy Policy shall be deemed accepted by you.

External Links: While our Services may contain links or integrations to other websites, social networks or services (including your ability to share information with social platforms, to use social platforms to create your account or to connect your account with respective social platforms), we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or services of such third parties, or interact with social network integrations. We recommend you read the privacy policies of each and every website and service you visit. This Privacy Policy only applies to our Services.

Children’s Privacy: Our Services are not intended for use by children under the age of 18. We do not knowingly collect personal data from minors under the age of 18 and do not wish to do so. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@smartbuyglasses.com.

EU and UK Representatives: SmartBuyGlasses has designated SmartBuyGlasses Sp. zo.o as its representative in the European Union, and SmartBuyGlasses Optical Limited as its representative in the UK for data protection matters pursuant to Article 27 of the GDPR and UK GDPR. Our EU and UK representatives may be contacted only on matters related to the processing of personal data. To make such an inquiry, please send an email to EUUKdata@smartbuyglasses.com.

Contacting Us: If you have any comments or questions about this Privacy Policy or if you have any concerns regarding your personal data held with us, please contact us at privacy@smartbuyglasses.com.

Cookie Policy for SmartBuyGlasses

What Are Cookies

As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to Your computer, to improve Your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how You can prevent these cookies from being stored however this may downgrade or 'break' certain elements of the site’s functionality.

How We Use Cookies

We use cookies for a variety of reasons detailed below. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that You leave on all cookies if You are not sure whether You need them or not in case they are used to provide a service that You use.

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on Your browser (see Your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that You visit. Disabling cookies will usually result in also disabling certain functionality and features of the site. Therefore, it is recommended that You do not disable cookies.

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.

• • Session cookies: These cookies only last as long as Your online session and disappear from Your computer or device when You close Your browser (like Internet Explorer or Safari).

• • Persistent cookies: These cookies stay on Your computer or device after Your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who You are for more than one browsing session. For example, we use them to remember Your preferences for the next time You visit.

• • 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.

• • Functional cookies: These help us personalise the SmartBuyGlasses to You by remembering Your preferences and settings.

• • Performance cookies: These help us understand how people are using the SmartBuyGlasses, so we can make it better, and they let us try out different ideas. We sometimes get other companies to analyse how people are using SmartBuyGlasses. These companies might set their own performance cookies. Some examples of how we use these cookies are: collecting information on which web pages visitors go to most often so we can improve our online services, making sure that the website is working properly and fixing any errors testing designs to help improve the look and feel of the website.