“Shanghai Light Care Technology Co., Ltd.” or “we” respects your right to privacy and protects your personal data. This Privacy Notice explains who we are, how we collect, share and use personal data about you, and how you can exercise your data subject rights, when using Opteyes mobile application and WeChat mini program (the “App“) . This policy applies to the products / services provided on the APP only. Please see “What is the business of Shanghai Light Care Technology Co., Ltd.” for the content of the products / services.
If you have any questions or concerns about our collection and use of your personal data, please contact us using the contact details provided at the bottom of this Privacy Notice.
This Privacy Notice is made in accordance with applicable Chinese data protection laws and regulations. The “personal data” under this Privacy Notice refers to any information, in electronic form or other form, that is able to directly or in combination with other information identify an individual or reflects an identified individual’s activities, including but not limited to name, identification number, correspondence address, residential address, account information, financial information, location data. Personal data includes the sensitive personal data under Chinese data protection laws and regulations.
If you are a minor under the age of 18
If you are a minor under the age of 18, you need to read this Privacy Notice and use our App under the guidance of your parents or legal guardian. We need the consent of your parent or guardian to allow you to register and use the App as well as to upload your personal data through the App.
If you are the parent or guardian of the minor, you can contact us by using the information provided in the section of “How to contact us” if you have questions concerning the personal data of the minor.
If the personal information of a minor is collected with his/her parents’ consent, we will only use or publicly disclose such information when permitted by law, with the explicit consent of his/her parent or guardian, or when necessary for the protection of the minor.
If we find out that we have collected the personal data of a minor without his/her parent or guardian’s prior explicit consent, we will delete related personal information without any delay.
What does Shanghai Light Care Technology Co., Ltd. do?
We are a vision care program that is tailored to the lives of modern-day professionals. We are the first on-site vision care provider to offer end-to-end eye care services and eyewear solutions in a connected digital experience.
What personal data does Shanghai Light Care Technology Co., Ltd. collect and why?
The personal data that we may collect about you broadly falls into the following categories:
Information that we collect automatically
When you visit our App, we may collect certain information about you automatically from your device.
Specifically, the information we collect automatically may include your following technical information.
Reservation: We may collect user’s name, phone number, birthday, calendar and other information through WeChat reservation;
APP: We may collect your photo and 3D face mesh of your face (“Facial Scan Data”). We will extract your face-width, nose-width, face shape, complexion, eye colour, hair colour and other statistical data from the user’s photo and 3D mesh of the user’s face (collectively “Facial Scan Data”)Facial Scan Data for the purpose of making recommendation of style and colour of the frame to you.
Collecting these categories of information that enables us to:
We will collect your facial measurements by capturing a facial scan, a facial photo, your lens prescription strengths and style preferences for recommending frame sizes and spectacles to you.
We will access to your phone camera to provide a live virtual try-on of different glasses for you.
We will collect your name, telephone number and address for delivery of your purchased products.
All the above data collected will be saved as a “Vision Profile” for your reference of possible future purchases.
The above collected data may be transferred and stored at a destination within or outside mainland China to enable us to provide and improve our services on the APP. For information about storage and cross-border transfer, please see the below part of “Data Retention” and “International Data Transfer”.
APP makes use of advanced phone capabilities (like TrueDepth camera on the iPhone) to capture your facial scan and facial photo. We don’t share your facial scan and facial photo with any third parties, we guarantee that we will not infringe your right of portrait by any means. We only use them to measure your facial features (like face-shape, nose-shape, skin-tone and face-width) for the purpose of identifying appropriate spectacles for you. We store the facial scan and facial photo securely on our servers. This allows us to provide updated recommendations without you having to perform face scans repeatedly.
In general, we will use the personal data we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal data. However, we may also use your personal data for other purposes that are not incompatible with the purposes we have disclosed to you (such as for statistical purposes) if and where this is permitted by applicable data protection laws.
Who does Shanghai Light Care Technology Co., Ltd. share your personal data with?
We may disclose your personal data to the following categories of third party data recipients with your prior consent and our notification of this Policy:
to our group companies, third party services providers and business partners who provide products and/or services to us, or who otherwise process personal data for purposes that are described in this Privacy Notice or notified to you when we collect your personal data.
to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) to comply with any applicable law and regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice;
In case of mergers, acquisition or insolvency or bankruptcy, if the new company or organization will receive your personal data from us, we will report to you about such changes. And we will request that the new company or organization that will continue to process your personal data in accordance with this Privacy Notice. If the new company or organization holding your personal data needs to use your personal data for purposes that are not disclosed in this Privacy Notice, the new company or organization will obtain your explicit consent again in accordance with applicable laws and regulations.
to any other person with your consent to the disclosure for the purpose that we will inform you before disclosure when getting your consent.
We will normally collect personal data from you only where we have your consent to do so, where we need your personal data that is truly necessary to conclude and perform a contract with you, or where there is a legal obligation on our part that requires us to collect, use or process your personal data for compliance purpose. In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person.
If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, this Privacy Notice will apply.
Tracking Technology Notice
We use Request device permission, error log and user data for improving user experience (collectively, “Tracking Technology”) to collect and use personal data about you.
You may reject our use of Tracking Technology by denying the request of device permission. Please note that when you reject our use of Tracking Technology to collect your personal data, will not be able to identify appropriate spectacles for you and use the live virtual try-on. But your rejection will not affect other functions in our APP.
How does Shanghai Light Care Technology Co., Ltd. keep your personal data secure?
We use appropriate technical and organizational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.
Location of storage: We will store the personal data that we collect from you within China in accordance with applicable Chinese laws and regulations and industry practice. However, for the purposes of this Privacy Notice, we may transfer some information to other countries outside China according to the provision hereafter (International Data Transfer).
Retention Period: Unless otherwise required by applicable laws and regulations, we would store your personal data for a period of time as below:
We retain personal data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). The retention period shall be the minimum duration necessary to realize the purpose of use authorized by the owner of such personal data.
When we have no ongoing legitimate business need to process your personal data or the statutory retention period under Chinese laws and regulations expires, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion or anonymization is possible.
De-identification: After collecting the personal data (including the personal sensitive data), we will conduct de-identified process immediately. Furthermore, we will isolate the de-identified personal data from the personal data which could be recovered to identify a person again.
The transfer and retention of personal sensitive data: We guarantee that we will take strict security measures to protect the personal sensitive data when transfer and store such personal sensitive data, including but not limited to take measures to protect the integrity of such personal sensitive data, and take measures to keep such personal information confidential in the process of transfer and storage.
When our company ends its operation: In case that our company ends its operation, we will stop to collect personal data at once and we will notify you about our current status. In addition, we will delete or anonymize the personal data that we have already collected.
The legal liability of our company: We will try our best to ensure the security of your personal data. If the security incident happens, we will notify you through reasonable and valid measure, and we will take corresponding legal liability.
International Data Transfer
In order to fulfill the purposes stated in this Privacy Notice, with your prior explicit consent, we may transfer your personal data to our affiliated companies or to our service providers located outside of China in accordance with the requirements under applicable Chinese laws and regulations. We will require such data receivers located outside of China to take appropriate measures to protect your personal data at a level that is equivalent to the personal protection afforded by Chinese laws and regulations, and to process your personal data pursuant to this Privacy Notice. We will also take appropriate measures such as pseudonymization to protect your personal data before the cross-border transmission of your personal data, where technically feasible.
Your Data Subject Rights
You have the following data protection rights:
You are entitled to any statutory data subject rights provided under Chinese laws, such as to access, correct, update and delete your personal data collected and processed by us. You may exercise your rights by contacting us using the contact details provided in the section “How to contact us”.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to Contact us” heading below.
You can de-register your account at any time. Please send an email (Please see contact us at the bottom) request to Shanghai Light Care Technology Co., Ltd. so that the staff of Shanghai Light Care Technology Co., Ltd. can remove the account from the system.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with the required time period and other requirements under applicable data protection laws and regulations.
We would not be able to respond to your request in the following circumstances:
Update of this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technology or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes to this Privacy Notice if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
How to contact us?
If you have any questions or concerns about our use of your personal data or regarding this Privacy Notice, please contact us using the following details: Shanghai Light Care Technology Co., Ltd. Company Address: Room 502, No. 686,Jiujiang Road, Huangpu District, Shanghai Contact: Opteyeschina@Opteyes.cn