PRIVACY POLICY

This Privacy Policy was last modified and is effective as of July 1, 2020.

Transitions Optical, Inc. and certain of its affiliated entities ("Transitions Optical", "we", "our", or "us") respect your privacy.  This Privacy Policy explains what information about you is collected when you visit the websites and mobile applications to which it is posted or use our services (collectively, "Digital Services").  It also explains your privacy rights and how we may use or share your information.

Please read this Privacy Policy carefully.  If you have any questions about this Privacy Policy or how to exercise your rights, please see the "Contact Us" section at the end of this Privacy Policy.

Special Note for Visitors Outside the United States: Transitions Optical, Inc. is a U.S. company, and the Digital Services are hosted within the U.S. The Digital Services, and the products or services that are offered on the Digital Services, if any, are intended only for residents of the U.S. and are not intended to target or otherwise solicit individuals residing outside the U.S., including those residing in the European Economic Area ("EEA").If you reside in the EEA or elsewhere outside the U.S., do not access or use the Digital Services.If you are attempting to access the Digital Services from outside the U.S., please note that the laws governing data collection, privacy, and use of your personal information may differ from the laws of your country of residence.If you are based in a jurisdiction outside the United States, such as the EEA, and would like to purchase products or services from a Transitions Optical company, please contact one of our affiliates within your jurisdiction for assistance.These affiliates will have their own Privacy Policies that govern the collection and use of your personal information in accordance with applicable law, including, for residents of the EEA, the European Union data protection and privacy laws.By accessing the Digital Services and/or sharing your personal information with Transitions Optical, you agree that the laws of the United States shall govern and you hereby expressly consent to the collection, transfer, and use of your data, in or to, the United States in accordance with the terms of this Privacy Policy.

1. Modifications to this Privacy Policy

Transitions Optical reserves the right to modify this Privacy Policy at any time by posting a revised version on the Digital Services.  Your continued use of the Digital Services after any such amendments signifies your acceptance thereof.  We encourage you to review this Privacy Policy each time you use the Digital Services.

2. Purposes of PII Collection

Through your use of the Digital Services, we may collect and maintain personally identifiable information ("PII") about you.  PII is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form.

PII You Provide:  The types of PII that may be collected on or through the Digital Services include your name, mailing address, email address, and telephone number.

Additional PII that may be collected on or through the Digital Services includes, but is not limited to:

·         Emails from Transitions Optical.  If you sign-up to receive emails about our products or services, we will collect your email address.

·         Find Your Transitions. If you use our "Find Your Transitions" feature, we will collect your mailing address.

·         Register Your Lenses.  If you register your lenses, we will collect your name, mailing address, and email address, date of birth, gender, purchase date, whether first pair, product.

·         Contact Us.  If you contact us by completing one of our online webforms, we will collect your name and email address, country, and phone number.  We also will collect any PII that you provide in our "comments" section.  If you submit an inquiry by email, we will collect your email address and any PII that you provide in that email communication.

·         Promotions.  If you enter a sweepstake, contest, giveaway or other promotion (each a "Promotion"), we will collect your name and age or birth date

·        Employment.  If you apply for employment, we will collect your name, email address, mailing address, telephone number, work authorization information, visa status, desired salary, academic level, employment history including salary, and any other information you include on the resume you upload to the Digital Services.  You may also choose to provide optional information such as race, gender, and whether you are disabled or your Veteran status.

·         Survey.  If you participate in a survey, we may ask your gender, age, income, ethnicity, family size and marital status. 

·         Sharing.  If you share an article or page of the Digital Services with a third party, we will collect the third-party email address.

  ·       Other Information.  If you use a service, we may collect information in order to provide the service you have requested.  For example, if you use the “Find Your Transitions” feature on our Site, we may collect certain additional information

PII Collected Automatically:  Our Digital Services capture certain non-personal common technical information automatically.  This information may include your Internet protocol (IP) address, browser type and computer operating system, device type, application software, time and date you visit or use the Digital Services, and traffic patterns and usage data, such as the pages you access, the address of the website that directed you to the Digital Services or the website you visit when you leave the Digital Services.  Transitions Optical uses this information to understand patterns of site activity, including aggregated user demographics, and to improve the Digital Services so they are more useful for you.

Location Information:  When you access our website, we will ask you to allow us to track your location.  We also may collect information regarding your general location using your IP address.  If you access or use the Digital Services from a mobile device, we may collect more precise geolocation information from your mobile device.  This information may be used to customize certain features of our Digital Services and to provide you with location-based services such as our “Find Your Transitions” feature.  This information may also be used to send push notifications, which appear on the display of your mobile device in the form of a badge, alert or banner, and allow mobile applications to send information to your mobile device even when the application is not in use.  For information on how to disable geolocation services and/or push notifications on a mobile device, see Section 7 below regarding your Opt-Out Choices.

3. Use of PII

We request PII to provide a service, product or information about Transitions Optical’s products or services or to complete a transaction.  Examples include subscribing to newsletters, emailing a friend an article from the Digital Services, entering a Promotion, participating in training, finding an eyecare professional or doctor, distributor, store or sales consultant, providing information regarding vision, vision care and vision correction, applying for employment, completing online surveys, contacting us with questions or comments, or for product registration.  We may also generally use your information, including PII, to:

·           Respond to your questions or comments or otherwise communicate with you.

·           Provide customer service.

·           Improve our products, services, marketing, and customer service.

·           For promotional purposes and to send you promotional communications.

·           Identify your preferences to customize our communications and marketing.

·           Manage communications and opt-out choices.

·           Provide information about Transitions Optical and our affiliated companies, their products, and services.

·           Provide information regarding vision, vision care and vision correction.

·           Allow you to schedule eye exams or similar appointments with professionals in your area.

·           Understand patterns of Digital Services activity and improve the Digital Services.

·           Conduct market research.

·           Prevent and investigate malicious activity, security breaches, and fraud.

·           Conduct analyses and for administrative purposes.

·           Administer and fulfill Promotions, including tax reporting.

4. Protection of PII

Although Transitions Optical employs physical and electronic security measures to protect PII, Transitions Optical cannot promise the use of our Digital Services is completely safe or that your PII will not be disclosed or misused, either by accident or by the unauthorized acts of others. Transitions Optical urges you to use caution when using the Internet.  This includes not sharing your passwords.

The Digital Services may contain customer reviews, forums and/or message boards and other Online Content.  Please remember that any information disclosed in these areas becomes public information, and you should exercise caution when considering the disclosure of your PII.  You agree that Transitions Optical is not responsible for material posted by you or others in these public forums.

5. Sharing of PII

Transitions Optical may share your information, including your PII, as follows:

·         Affiliated Entities. Transitions Optical may transfer PII to its affiliated entities, including future affiliated entities.

·         Consultants and Service Providers. Transitions Optical will disclose PII to third party consultants, vendors, and service providers (such as providers of hosting, support, maintenance and remedial, repair services, mail delivery services, evaluation data analysis, data cleansing, order fulfillment and shipping, Promotion administration and fulfillment, advertising, marketing and promotional activities, fraud protection and risk reduction, and payment processing and authorization) to the extent that they require access to our databases, or the PII contained in our databases, to provide services to you or Transitions Optical.

·         Joint Promotion Partners.  Sometimes we conduct joint promotions with third parties.  If you register for one of those joint promotions your information may be collected by both Transitions Optical and the third party.  Or, we may give you the option to have us share your information with the promotion partner.  Your information will be used by us and/or by them as described in our posted privacy policies.

·         Enforcement of Rights/Security. Transitions Optical reserves the right to release PII (i) when Transitions Optical is under legal compulsion to do so (e.g., we have received a subpoena) or Transitions Optical otherwise believes that the law requires us to do so, (ii) when Transitions Optical believes it is necessary to protect and/or enforce the rights, property interests, or safety of Transitions Optical, our users or others, or (iii) as Transitions Optical deems necessary to resolve disputes, troubleshoot problems, prevent fraud and otherwise enforce the Privacy Policy and Terms of Use.

·         Reorganization or Sale of the Company. In the event that Transitions Optical is merged with or becomes part of another organization, or in the event that Transitions Optical is sold or it sells all or substantially all of its assets or is otherwise reorganized, the PII Transitions Optical collects will be one of the transferred assets to the acquiring or reorganized entity.

·         Third-Party Marketing.  Transitions Optical may share your PII with third parties for their marketing purposes.

·         As Otherwise Allowed by Law. Transitions Optical may transfer PII to third parties where we are expressly authorized by applicable law to do so.

·         Non-PII.  Transitions Optical may transfer your non-PII to third parties for any lawful purpose.  This non-PII may include aggregate information, which is compiled information reflecting the collective usage of multiple users, and/or de-identified information, which reflects the usage patterns of a particular use of the Digital Services, as opposed to users collectively, but is not personally identifiable.

6. Children’s Privacy

Our Digital Services are meant for adults.  Our Digital Services are meant for adults. We do not knowingly collect PII from children under 13. If you are a parent or legal guardian and think your child under the age of 13 has given us information, you can contact us to remove the information. In addition, California minors (under 18 years of age) may in certain circumstances request and obtain removal of content or information they posted to the Digital Services. If you are a California minor, you may contact us to make a removal request. You may submit a removal request through our interactive webform available here or by calling us toll-free at 1-866-448-8808.

7. Your Choices Regarding Collection of Information

Marketing Emails.

You can opt out of receiving future promotional emails from Transitions Optical by following the unsubscribe procedures indicated in each email.  Even if you opt out of receiving promotional emails from Transitions Optical, we will send you transaction emails and respond to questions from you.

Cookies and other Technologies.

Transitions Optical uses cookies, which are small data files created by a Web server and stored by your browser, to keep track of and enhance certain user activities on our Digital Services such as logging into your account, making a purchase and other user-specific features. We also use cookies and web beacons (also known as pixel tags, action tags, or transparent GIF files), which are tiny graphic images, to permit our Digital Services to function properly, to implement analytics tools, including Google Analytics, that help us understand how the Digital Services are performing and how visitors engage with the Digital Services, and to improve and track our advertising and marketing, including how you interact with our advertisements and communications. For more information on Google Analytics, visit: https://www.google.com/policies/privacy/partners/.

You may block or restrict cookies on your computer or device or purge them from your browser by adjusting your web browser preferences. You should consult the operating instructions that apply to your browser or your mobile device’s user guide for instructions on how to configure your setting to meet your preferences.  Cookies allow you to take advantage of some features or functions of the Digital Services, so if you block or otherwise reject our cookies, you may not be able to use some features of the Digital Services. If you don’t want your browser to share information with Google Analytics, you may download an Opt-out Browser Add-on by visiting https://tools.google.com/dlpage/gaoptout. Please note that the Add-on does not prevent information from being sent to Transitions Optical.

Interest-Based Behavioral Advertising. Transitions Optical’s advertisements are shown on third party websites, including Google. Transitions Optical may use technologies such as cookies and web beacons to help manage online advertising. These technologies are provided by our third party vendor(s) and enable our third party vendor(s) to recognize a unique cookie placed by us (when you accessed the Digital Services) or by our third party vendor(s), or by another advertiser who works with our third party vendor(s). These technologies allow us to learn which advertisements bring users to our Digital Services. They also allow us to collect information about your online activities over time and across third party websites so we can manage advertising effectiveness and provide you with online advertisements, including advertisements on the websites of third parties not affiliated with Transitions Optical, more likely to be of interest to you. Third party vendors, including Google, use cookies to serve ads to you based on your past visits to the Digital Services. With this technology, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address. For more information about online behavioral advertising and your choice to opt-out of receiving targeted online advertisements from members of the Digital Advertising Alliance (DAA), please visit the DAA website at http://www.aboutads.info/choices/. To opt-out of targeted advertising from members of the Network Advertising Initiative (NAI), please visit the NAI website at http://www.networkadvertising.org/choices/.  To learn how you can opt-out of Google’s use of cookies, please visit Google’s Ad Settings at: https://adssettings.google.com.

Tools on Mobile Devices. You can control the tools on your mobile devices. For example, you can turn off the GPS locator or push notification on your phone. Please consult your mobile device’s user guide for instructions on clearing cookies, disabling location services, and disabling push notifications.

Do Not Track ("DNT") Signals.  Some Internet browsers offer a DNT feature that signals to websites you visit that you do not want to have your online activity tracked.  There is currently no uniform way that browsers communicate DNT signals.  Transitions Optical does not currently interpret, respond to, or alter its practices when it receives DNT signals but may do so in the future.

8. Accessing and Updating your PII

You may contact us to update your PII. See the "Contact Us" section at the end of this Privacy Policy.

9. Consent of data Transfer of Non-U.S. Residents

If you reside in a country other than the United States, upon providing your PII to Transitions Optical, you will be indicating your explicit consent that the PII you have provided may be transferred to, processed, and stored in the United States.

10. Links to Other Websites

Other Transitions Optical Websites and Digital Platforms. This statement applies only to the Transitions Optical Digital Services on which it is posted. Other websites of Transitions Optical and affiliates, mobile websites, social media sites and other digital platforms may have different privacy policies so please be sure and read the privacy policy of each website, mobile website, social media site and other digital platform that you visit to understand how Transitions Optical or its affiliate collects and uses information and under what circumstances Transitions Optical or its affiliate shares information about you collected through that website, mobile website, social media site or other digital platform.

Third Party Websites and Digital Platforms. The Digital Services may contain links to third party sites and digital platforms. Transitions Optical is not responsible for the content or policies of such sites and platforms and recommends that you review the privacy policy posted on each third party website and digital platform that you visit.

11. Notice to Nevada Residents

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information.  Subject to a number of exceptions, Nevada law defines "sale" to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons.  We do not currently sell personal information as defined in the Nevada law.  However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes.  Opt-out requests may be sent privacyusa@transitions.com.

12. Notice to California Residents

The California Consumer Privacy Act (CCPA) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information.

The CCPA defines "personal information" to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  Personal information does not include information that is publicly available, deidentified or aggregate information.  For purposes of this "Notice to California Residents" section we will refer to this information as "Personal Information."

Right to Know About Personal Information Collected, Disclosed, or Sold

            Your Right

If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you.  This right includes the right to request any or all of the following:

·         Specific pieces of Personal Information that we have collected about you;

·         Categories of Personal Information we have collected about you;

·         Categories of sources from which the Personal Information was collected;

·         Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;

·         Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and

·         The business or commercial purpose for collecting or, if applicable, selling Personal Information.

The CCPA defines "sell" to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

            How to Submit a Request to Know

You may submit a request to know through our interactive webform available here or by calling us toll-free at 1-866-448-8808.            Our Process for Verifying a Request to Know

If we determine that your request is subject to an exemption, we will notify you of our determination.  If we determine that your request is not subject to an exemption, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. 

We will verify your identity as follows:

Request to Know Categories of Personal Information: We will verify your identity to a "reasonable degree of certainty" by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

Request to Know Specific Pieces of Personal Information: We will verify your identity to a "reasonably high degree of certainty" by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities.  In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

            Collection of Personal Information

The following table presents the categories of Personal Information that we have collected, the categories of sources from which that information was collected, and the categories of third parties with whom we shared that Personal Information for the 12 months preceding the Effective Date of this Privacy Policy.

Categories of Personal Information CollectedCategories of Sources from which Personal Information was CollectedBusiness or Commercial Purpose for the CollectionCategories of Third Parties with whom We Share Personal Information
NameConsumerProviding customer serviceAffiliates
Business partners
External marketing entities
Email AddressConsumerProviding advertising or marketing services
Providing customer service
Inducing another person to buy products, goods, property, information or services
Same above
Postal address and telephone numberConsumerProviding customer serviceSame as above
Internet Protocol addressConsumerAuditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
Providing advertising or marketing services
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Affiliates
Data analytics providers
Advertising networks
Cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; information regarding consumer’s interaction with website, application or advertisementConsumerSame as aboveSame as above
Browsing history, search historyConsumerSame as aboveSame as above
Geolocation dataConsumerProviding customer service
Providing advertising or marketing services
Same as above
Any commercial information collected such as records of products purchased, obtained or considered.ConsumerProviding customer serviceAffiliates
Data analytics providers

            Disclosure or Sale of Personal Information

We have not sold any Personal Information in the 12 months preceding the Effective Date of this Privacy Policy.

Right to Request Deletion of Personal Information

            Your Right

If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected or maintain.  However, a business is not required to comply with a request to delete if it is necessary for the business to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

            How to Submit a Request to Delete

You may submit a request to delete through our interactive webform available here or by calling us toll-free at 1-866-448-8808.

If you submit a request to delete online, you will be asked to confirm separately that you want your Personal Information deleted.

            Our Process for Verifying a Request

If we determine that your request is subject to an exemption, we will notify you of our determination.  If we determine that your request is not subject to an exemption, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. 

We will verify your identity either to a "reasonable degree of certainty" or a "reasonably high degree of certainty" depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized deletion.

We will verify your identity to a "reasonable degree of certainty" by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

We will verify your identity to a "reasonably high degree of certainty" by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities.  In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

If we are unable to verify your identity to the applicable standard, we will treat your request to delete as a request to opt-out of the sale of the personal information that you provided as part of processing the request to delete.  See the following section for a description of the right to opt-out of the sale of personal information.

Notice of Right to Opt-Out of Sale of Personal Information

            Your Right

If you are a California resident, you have the right to direct a business that sells (or may in the future sell) your Personal Information to stop selling your Personal Information and to refrain from doing so in the future.

The CCPA defines "sell" to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

            How to Submit a Request to Opt-Out

You may submit a request to opt-out of sales through our interactive webform available here.  You also may submit a request by calling us toll-free at 1-866-448-8808.

            How We Process a Request to Opt-Out

We will act upon your request to opt-out within 15 days from the date that you submit the request.  The CCPA does not require that we verify the identity of individuals who submit requests to opt-out of sales.  However, we may deny the request if we have a good-faith, reasonable, and documented belief that the request is fraudulent.  If we deny the request on this basis, we will notify the requesting party and provide an explanation why we believe the request is fraudulent.

Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section "Notice to California Residents."  As such, we will not deny goods or services to that California resident; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to the California resident; or suggest that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services.  However, we are permitted to charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.

Authorized Agents

California residents may use an authorized agent to submit a request to know, delete, or opt-out of sales on your behalf.

If you use an authorized agent to submit a request to know or request to delete, we may require that (1) the authorized agent provide proof of your written permission and (2) you verify your identity directly with us.  These requirements do not apply if you have provided the authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465.

If you use an authorized agent to submit a request to opt-out of sales, you will need to provide that authorized agent with written permission to do so and submit written proof to us that the agent has been authorized to act on your behalf.

Shine the Light Law

Under California’s "Shine the Light" law, California residents who provide PII in obtaining products or services for personal, family, or household use are entitled to request and obtain from Transitions Optical once a calendar year information about the PII we shared, if any, with other businesses for their own direct marketing uses.  If applicable, this information would include the categories of PII and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.

To obtain this information, please email privacyusa@transitions.com, with "Request for California Privacy Information" on the subject line and in the body of your message.  We will provide the requested information to you at your e-mail address in response.

Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

13. Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities.  If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

14. How to Contact Us

To contact us for questions or concerns about our privacy policies or practices please email us at privacyusa@transitions.com.

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