6over6 PRIVACY NOTICE         

Effective Date: July 3, 2019

6 Over 6 Vision Ltd. and its affiliates (“6over6“, “we”, “us”, or “our”) are on a mission to democratize access to vision care and help the whole world see clearly, by utilizing our suite of mobile optometry tools to measure the required optical parameters of their glasses or eyesight.

This Privacy Notice describes our practices concerning the data we receive or collect when you visit our websites (www.6over6.com and www.glasseson.com) (the “Sites”), install or use our GlassesOn mobile applications, SDK and software tools (the “App” and “SDK”, respectively), or use our online platform, hosted on the Sites (together with the Sites, App and SDK – the "Services").

Specifically, this Privacy Notice describes our practices regarding:

  1. Data Collection
  2. Data Uses
  3. Data Location and Retention
  4. Data Sharing
  5. Cookies and Tracking Technologies
  6. Communications
  7. Data Security
  8. Data Subject Rights
  9. Children
  10. Data Controller/Processor
  11. Updates & How to contact us

 Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please discontinue and avoid using our Services.

You are not legally required to provide us with any Personal Data (defined below), but without it we may not be able to provide you with the full range of Services or with the best experience when using our Services.

 

 

1.   Data Collection

We collect Personal Data regarding our Users, as well as data regarding Visitors. Such data is typically collected and generated through the Visitor’s or User’s interaction with our Services, through automatic means, directly such Visitor or User, or other third parties.

Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data”):

  1. Data automatically collected or generated: When you visit, interact with or use our Services, we may collect or generate certain technical data about you. We collect or generate such data either independently or with the help of third party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below).

Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, non-identifying data regarding a device (such as type, screen resolution), operating system, various apps usage statistics, browser version, locale and language settings used, general User location (country), date and time stamp, types of advertisements viewed and click data, the pixels installed on our user’s device, type and version of such device, language settings, browser type and version, and the length of time a User is using the Services and the activity (clicks and other interactions) of Visitors and Users in connection with our Services. Such data does not enable us to learn a person’s true identity or contact details. We mainly use this data to gain a better understanding on how Visitors, Users typically use and interact with our Services; how we could improve their user experience; to optimize our product; and to optimize the overall performance of our Services.

  1. Data received from our Users: You may provide us with Personal Data such as your first and last name, address, email, contact details, as well as any other Data you choose to provide when you use our Services or contact us.

Customers may provide us additional Data such as their mobile phone number (only as part of the download process of App, and without retaining such number once the App is installed, Eye glasses parameters, lens analysis and pupillary distance; a frontal facial picture; and a "Calibration Image" which is an image with a known size (such as plastic standard magnetic card) to allow the Services to create 3D model from 2D image or set as a reference object (see: http://www.6over6.com/faq). Please note that when a magnetic card is identified in the image, we make reasonable efforts to apply an obfuscation process, so to avoid saving any recognizable details on the card itself on our systems. This Calibration Image will not be linked to any Personal Data.

 

2.   Data Uses

We use Personal Data as necessary for the performance of our Services; to comply with applicable law; and to support our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our marketing and advertising services, customer service and support operations, and protecting and securing our Users, ourselves and our Services.

Specifically, we use Personal Data for the following purposes:

  1. To facilitate, operate, and provide our Services;
  2. To provide our Visitors and Users with assistance and support;
  3. To further develop, customize and improve the Services and the  general user experience, based on common or personal preferences, experiences and difficulties;
  4. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
  5. To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
  6. To comply with any applicable laws and regulations.

3.   Data Location & Retention

Data Location: Your Personal Data may be maintained, processed and stored by our authorized affiliates and Service Providers (defined below) in the United States of America, the EU and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.

6Over6 is headquartered in a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents. While privacy laws may vary between jurisdictions, 6Over6, its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Notice and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

Data Retention: We retain Users’ Personal Data for as long as a session has not been completed, and we have not been notified otherwise, or as long as we consider necessary for the purposes described herein.

We keep Visitors’ Personal Data for as long as reasonably necessary in order to maintain and expand our relationship and to provide them with our Services.

We will also retain your (User) Personal Data for as long as is required 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), in accordance with our data retention policy.

Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete 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 at privacy@6over6.com.

4.   Data Sharing

Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled 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.

Service Providers: We may engage selected Third Party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, user engagement services, e-mail distribution and monitoring services, and our business, legal and financial advisors) (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.

One of our Service Providers in particular is a tool called “Google Analytics”, used by us to collect information about use of our Services. Google Analytics collects information such as how often users visit the Services, what pages they visit when they do so, and what other sites they used prior to coming to our Services. We use the information we get from Google Analytics to maintain and improve the Services and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable data. 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, available at https://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at https://policies.google.com/privacy. You can learn more about how Google collects and processes data specifically in connection with Google Analytics at https://policies.google.com/technologies/partner-sites. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

Business Transactions: We may share your eye glasses parameters or PD and other unique identifiers with an approved business associate only for the purpose of allowing you to make business transactions upon your request (e.g. transferring your eye glasses parameters (using a standard SSL and HTTPS protocols) to an online retailer selected by you, for you to be able to purchase glasses); such data may then be retained with such party, who will become the Data Controller (as further explained in Section 10 below).

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 6Over6, any of our Users  or any members of the general public.

6Over6 Subsidiaries and Affiliated Companies: We may share Personal Data internally within our group for the purposes described in this Privacy Notice. In addition, should we or any of our subsidiaries or 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. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

For the avoidance of doubt, 6Over6 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. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

5.   Cookies and Tracking Technologies

Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns.

A “cookie” is a small text file that is used, for example, to collect data about activity on our Site. Some cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by the User. We recommend the use of cookies for an optimal user experience of our Services.

While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

If you wish to prevent the use of your mobile device's advertising ID, you may change your device settings to reset such advertising ID (typically, this is available under the "Privacy" or "Ads" section in your device settings). You may also change your browser settings to reset or block cookies (typically, this is available under the "Settings" or "Help" section in your browser menu). The types of cookies we use are set out below:

1.        Performance Cookies: This type of cookie helps us to secure and maintain our Sites, and remembers your preferences for tools found on the Sites, so you don’t have to re-set them each time you visit.

2.        Analytics Cookies: Every time someone visits our Sites, the analytics services we use generate Cookies which can tell us whether or not you have visited the Sites in the past, and provide additional information regarding how our users use our Sites (such as where users tend to click on our Sites). Your browser will tell us if you have these Cookies and, if you don’t, we generate new ones. This allows us to track how many individual users we have and how often they visit the Sites.

3.        Third Party Integration Cookies: On some of our Platforms, Third Parties may also set their own Cookies. They do this to track the performance of their applications that are integrated with our Sites, or to customize their services for you. Because of how Cookies work, we cannot access these Cookies, nor can these Third Parties access the data in Cookies we use on our Sites.

 

Cookie Name

Domain

Type

Description

logglytrackingsession

web.glasseson.com

Third party + Analytics

3rd party integration - used for logging system data

*mixpanel

mixpanel.com

Third party + Analytics

3rd party integration - used for anonymous data analytics

laravel_session

glasseson.com

Performance

Used for ‘session based’ temporal data to save communications on 6Over6’s servers

glasseson

glasseson.com

Performance

Used for inner system data to make our eye tests quicker and more secure

 

6.   Communications

Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, reports, service changes, etc. We may also send you notifications, messages and other updates. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.

Notifications and Promotional Communications: We may send you notifications concerning messages and other updates in your account. We may also send you notifications about new features, offerings, events and special opportunities or any other information we think our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, push 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 us at any time by sending an e-mail to support@6over6.com, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

7.   Data Security

In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any Third Parties as described in Section 4 above.

8.   Data Subject Rights

If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR), to request access to, and rectification or erasure of your Personal Data held with 6Over6, or to restrict or object to such Personal Data’s processing, or to port such Personal Data – please contact us by email at privacy@6over6.com.

Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.

9.   Children’s Privacy

Our Services are not designed to attract children under the age of 16. We do not knowingly collect Personal Data from minors under the age of 16 and do not wish to do so. If we learn that a person under the age of 16 is using the Services without parental consent where appropriate, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at privacy@6over6.com.

10.       Data Controller/Processor

Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller”, who determines the purposes and means of processing; and the “Data Processor”, who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

6Over6 is the “Data Controller” of its Visitors and User’s Personal Data, and with respect to which, assumes the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Notice.

If any of our Users instruct us to transfer their data to any of our partners, such as an online retailer to buy glasses from based on such data, such partner shall be deemed a “Data Controller” of their data. If any of our customers, partners or users submits any Personal Data concerning its own users (for example, Users of a service or mobile app operated by our partner, which utilizes 6Over6’s technologies), or otherwise has any of its Users submit or upload Personal Data in connection with our Services, such  partner shall be deemed the “Data Controller” of its End-Users’ data, and 6Over6 will process such Data on this partner’s behalf, as its “Data Processor”.

This means that in such cases, we will process such Users’ data on behalf of our partner, and in accordance with its reasonable instructions, subject to our Terms of Use and other commercial agreements. The partner will be solely responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).

If you are a User of any of our partners' services, please note that 6Over6 only processes your data solely on their behalf. Accordingly, if you would like to make any requests or queries regarding Personal Data we process on our partner’s behalf, please contact such partner directly. 

For example, if you wish to access, correct, or delete data processed by 6Over6 on behalf of a partner, please direct your request to the relevant partner (who is the “Data Controller” of such data).

Should we receive such requests directly, we may refer them to our partner.

 

11.       Additional Notices

Updates and Amendments: We may update and amend this Notice from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is so published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or application of such third parties and to read the privacy policies of each and every website and service you visit. This Notice applies only to our Services.

Questions, Concerns or Complaints: If you have any comments or questions about this Privacy Notice or if you have any concerns regarding your Personal Data, please contact us by email at privacy@6over6.com. 6Over6’s appointed Data Protection Officer may be reached by email at dpo@6over6.com.

GDPR-Rep.eu has been designated as 6Over6’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. GDPR-Rep.eu may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please send an email to privacy@6over6.com.

If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.