CCPA PRIVACY NOTICE

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we, Optimax Investment Ltd., together with its subsidiaries, affiliates, or related companies (“Company”, “our”, “we” or “us”) provide California residents (consumers or employees) with notice at collection ("CCPA Notice"). The CCPA Notice shall disclose the Personal Information (as defined below) that is collected, processed and shared during the use of the Services, and your rights.

The CCPA Notice is an integral part of our Privacy Policy; capitalized terms used but not defined in this CCPA Notice will have the meanings set out in the Privacy Policy or as defined under the CCPA or CPRA. If there is any conflict or inconsistency between the terms of this CCPA Notice and the Privacy Policy, the terms of this CCPA Notice will prevail solely for eligible consumers. We collect “Personal Information” which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device, all as detailed in the table below.

Personal Information under the CCPA further includes Sensitive Personal Information (“SPI”) as detailed in the table below.

Personal Information does not include: Publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; Information excluded from the CCPA or CPRA scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

We may have collected the following categories of Personal Information within the last twelve (12) months:

CATEGORY	EXAMPLE	COLLECTED
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	Yes: real name, shipping or billing address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and phone number.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes: name, age, gender, physical characteristics or description (vision tests), partial credit card number, health insurance policy number and medical information regarding eye care treatment when applicable, including prescription.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes: Gender.
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes: purchase habits, shopping history, transactions, partial credit card number.
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Yes: information we collect in relation to our Virtual Try-On tool may constitute biometric information under the CCPA. For more information on our processing of information that may constitute biometric information in relation to our Virtual Try-On tool, please review our Privacy Policy available here.
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes: browsing history and search history within and outside our Properties, interaction with our Properties and our advertisement.
G. Geolocation data.	Physical location, approximate location derived from IP address or movements.	Yes: approximate geolocation extracted from IP, physical location and GPS when using the App and approving the GPS permission.
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes: pictures uploaded to the site, and recording customer service calls.
I. Professional or employment-related information.	Current or past job history or performance evaluations.	Yes: Governed by the Employee Privacy Policy. Please review if you are our employee, for candidates, please review the Candidate Policy.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes: gender, certain demographic data, profiling. The profiling is not based on SPI.
L. Sensitive personal information.	Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life.	No

• Directly and indirectly from your actions within the Properties.
• Directly from you when you contact us, use the VTO tool, purchase, respond to a survey or provide feedback.
• From third-parties, advertising and analytic vendors, advertising networks, social networks share information with us when you log in, data enrichment vendors, etc.

For more information, please review our Privacy Policy. We may use the Personal Information collected as identified above, for the following purposes: to fulfill or meet the reason you provided the Personal Information (support, respond to a query, review create an account, use the VTO, purchase and deliver glasses and lenses, etc.); monitor and improve our Properties or Services; provide the Services; marketing our Services; analyzing our Services, Properties and your use of the Services and Properties; respond to law enforcement; or otherwise as detailed in our Privacy Policy.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. We may disclose your Personal Information to a contractor or service provider for a Business Purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract; we further restrict the contractor and service provider from selling or sharing your Personal Information. In the preceding twelve (12) months, we might have disclosed the following categories of Personal Information for a business purpose:

"BUSINESS PURPOSE (AS DEFINED UNDER CCPA)"	"DATA CATEGORY (CORRESPONDING WITH THE TABLE ABOVE)"	CATEGORY OF RECIPIENT
Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.	Category A Category D Category F Category G	Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.	Category A Category B Category F	Subsidiaries, operational partner, security and fraud prevention providers, operating systems.
Debugging to identify and repair errors that impair existing intended functionality	Category A Category B Category F	Analytic providers, operational partner, security and fraud prevention providers, operating systems.
Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.	Category A Category D Category F Category G	Advertising networks; data analytics providers; social media networks.
Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.	Category A Category D Category E Category F Category G Category H	Payment processors, fraud prevention providers, payment orchestration providers, VTO providers for the sole purpose of providing the services, subsidiaries, affiliated companies, operating systems, CRM, ERP, shipping partners, health care providers, health insurance, Trust Pilot or other survey providers, customer support, cloud computing and storage vendors, fulfillment vendors, frames and lens vendors, etc.
Undertaking internal research for technological development and demonstration.	Category A Category D Category F Category G Category H	Developers, operating systems, cloud and hosting providers, SaaS platforms for task management and development, customer support and optimization tools.
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned or controlled by the business.	Category A Category D Category F Category G Category H Category K	Developers, operating systems, cloud and hosting providers, security providers, SaaS platforms for task management and development, customer support and optimization tools.
Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you.	Category A Category D Category F Category G Category K	Advertising networks; data analytics providers; social media networks. Marketing service providers and technical platforms such as E-mail and text messaging providers, CRM and tracking tools (tracking within the Properties).
Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.	Category A Category D Category F Category G Category K	Advertising networks; data analytics providers; social media networks. Marketing service providers and technical platforms such as E-mail and text messaging providers, CRM and tracking tools (tracking within the Properties).

We do not “sell” or “share” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Information in direct exchange for money or some other form of payment.

For retargeting and analytic purposes, when we promote our Properties and advertise our products, we use third-party providers and tracking tools, advertising networks and social media. They provide these services by placing cookies, pixel or other tracking technology on our Properties and sharing with these vendors the online identifiers and online behavior information. The CCPA defines these actions as “sharing” or “selling”.

In the preceding twelve (12) months, we “sell” or “share” the following categories of Personal Information for a business purpose:

PURPOSE OF SALE OR SHARE	DATA CATEGORY (CORRESPONDING WITH THE TABLE ABOVE)	CATEGORY RECIPIENT
Targeted advertising, CCBA, promoting the Properties and Services, analytics and	marketing tools, analytic tools, advertising networks, social media networks, media buying, search platforms.	Category A Category F Category G

We do not knowingly collect information from children under the age of 16. The retention periods are determined according to the following criteria:

1. For as long as it remains necessary in order to achieve the purpose for which the Personal Information was initially processed.
2. To comply with regulatory obligations. For example: transactional data will be retained for up to seven years (or even more under certain circumstances) for compliance with our bookkeeping obligations purposes.
3. To resolve a claim, we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.

If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge, except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law, all as detailed herein:

CALIFORNIA PRIVACY RIGHT	DETAILS
The right to know what Personal Information the business has collected and access rights.	The right to know what Personal Information the business has collected about the consumer, including the categories of personal information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom the business discloses Personal Information, and the specific pieces of Personal Information the business has collected about the consumer. You can exercise your right by reviewing this Notice and the Privacy Policy, in case you would like to receive the specific pieces please fill in this form to receive a copy of your data: https://privacy.saymine.io/GlassesUSA.
Deletion Rights.	The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions. You can exercise your right for deletion in the following ways: Through the App settings. Through this link: https://privacy.saymine.io/GlassesUSA We reserve the right to reject such request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, ensure the security and integrity, provide the services, a legal obligation, etc.
Correct Inaccurate Information	The right to correct inaccurate Personal Information that a business maintains about a consumer. At any time, you may correct any of the account data we collect, or otherwise you may contact us at: privacy@ottica.com.
Opt-Out of Sharing for Cross-Contextual Behavioral Advertising (“CCBA”) or from selling, where applicable.	You have the right to opt-out of the “sharing” of your personal information for “cross-contextual behavioral advertising,” often referred to as “interest-based advertising” or “targeted advertising”. You may opt out through the “do not sell or share my personal information” button available within the Properties’ footer or within the App settings. You may further opt out through device settings (opt-out from tracking AAID, ADID, please see the following for information applicable to all devices: https://thenai.org/opt-out/mobile-opt-out/). Further, you can opt-out from interest-based advertising, CCBA, by using Self-Regulatory Program for Online Behavioral Advertising such as: Digital Advertising Alliance’s (“DAA”): https://www.aboutads.info/choices and https://www.aboutads.info/appchoices, and the Network Advertising Initiative (“NAI”): https://www.networkadvertising.org/choices. Last, you are able to install privacy-controls in the browser's settings to automatically signal your opt-out preference to the websites you visit (like the “Global Privacy Control”). We honor the Global Privacy Control as a valid request to opt-out of the sharing of information linked to your browser. In any event, please keep in mind: Opt-out tools are limited to the browser or device you use because they work off your browser ID and device ID. If you’re not signed-in to your customer account or don’t have a customer account, you will need to opt-out on each browser and device you use. Your browser may save some information in its cookies and cache to maintain your privacy preferences. Clearing these may remove opt-out preferences, requiring you to opt-out again. If you opt-out, you will still see ads online, but these ads will not be based on your inferred interests. Some automated means may still be used to collect information about your interactions with our online services for the other purposes such as to remember user preferences or enable specific functionality. We use necessary cookies to make our Properties work. Necessary cookies enable core functionality such as security, network management, and accessibility. You cannot disable those. You can read more about targeted adverting and take additional steps to control targeted advertising from many ad networks and exchanges by visiting the Digital Advertising Alliance (www.optout.aboutads.info). As online environments continue to evolve, additional opt-out mechanisms or privacy settings may become available to you. We encourage you to review the information on opt-outs and settings that browser owners, device manufacturers, technology companies, and industry associations make available to you.
Non-Discrimination	The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicants, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc.
Data Portability	You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format. In case you would like to receive the specific pieces please fill in this form to receive a copy of your data: https://privacy.saymine.io/GlassesUSA.

To learn more about California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.

Note: You may only exercise this right, unless legally required otherwise, twice within 12 years. We may, at times, offer you various financial incentives such as loyalty programs, discounts and special offers when you provide us with contact information and identifiers such as your name and email address. When you sign-up for our loyalty program, email list or other discounts and special offers, you opt-in to a financial incentive. You may withdraw from a financial incentive at any time by opting out from our email or closing your loyalty member account. Generally, we do not assign monetary or other value to Personal Information, however, California law requires that we assign such value in the context of financial incentives. In such context, the value of the Personal Information is related to the estimated cost of providing the associated financial incentive(s) for which the information was collected. You can end program participation at any time by contacting us at privacy@ottica.com to unsubscribe or cancel your participation in any program. We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. privacy@ottica.com This notice was last updated on July 11, 2023. As required under the CCPA, we will update our Privacy Policy every 12 months. The last revision date will be reflected in the “Last Modified” heading at the top of this Privacy Policy. California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at: privacy@ottica.com Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.