Urbanmilawear Privacy Policy

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

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

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

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

1. Data Collection and Processing

• Usage data: When you interact with our Services, we may process your personal data including IP addresses and approximate location based upon such IP addresses, digital identifiers, device data (like type, OS, device id, browser version, locale and language settings used), user agent, activity logs, session recordings, the cookies and pixels installed or utilised on your device (see Section 5) and inferred or presumed data on or generated from your use of the Services.
• Customer data: When you register for a membership with us via the Services, complete an order with us, or otherwise engage with us via the Services, including through the features we offer (for example the Lens Scanner, Pupillary Distance tool, or Virtual Try-On features), we may process personal data, including contact and profile information (name, email, phone number), eyeglass prescription (where this is provided to us by way of an optical script, we collect information contained in that script, for example your optician’s details and any other personal data contained therein), Pupillary Distance, physical address, gender, birth date, account activity (including payment method and details, transaction history, purchasing and product preferences and patterns), military or veteran status (when applying for the military discount), government-issued identity numbers, for example, TaxID (where relevant for customs purposes) and health ID (if included in your physical optical prescription), details about your insurance policy, including insurance provider (where you provide these to us to facilitate an insurance claim), and any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement.
• Feature data: Some of the features we offer via the Services, such as the Lens Scanner or Virtual Try-On (“VTO”) feature process additional types of personal data. When using the Lens Scanner, we may process personal data including optical data, such as glasses parameters, lens analysis, lens power, pupillary distance, and optical prescription.
  When using the VTO feature, we may process data including a capture of your face measurements and scan of your facial geometry. The VTO technology operates on an estimation of a standard 3D facial geometry, based on the image you submit via the Services (mathematic points that can be found on every face) to create a facial reconstruction and show you how you may look in the respective eyewear frames you have chosen to activate, in real time. Your image is immediately deleted once this reconstruction has occurred.
  When using the Pupillary Distance Tool, we may process personal data including pupillary distance.
• Business contact data: If you engage with us in your professional capacity, provide a professional service to us, or explore potential business opportunities or partnerships with us, we may process the following types of data: name, email address, phone number, position, workplace, contractual and financial documents, and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement.

We collect and generate this information:

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

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

2. Data Uses

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

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

3. Data Location and Retention

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

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

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

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

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

4. Data disclosure

We disclose personal data in the following ways:

• Service Providers: We engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers may include commercial software providers, hosting and server co-location services, communications and content delivery networks, data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, content transcription and analysis services, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, website chat services, optical solution technology providers, delivery or logistics providers, our legal, financial and compliance advisors, and our contractors (for example, our opticians) (collectively, “Service Providers“). Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.
• Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data in response to a legal request, such as a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interest, including the security or integrity of our products and Services.
• Event Partners: If you register for any event that we host, organise or sponsor, then with your permission we may share your registration details with others, including the hosts, organisers, speakers, service providers, and sponsors of that event, so that they may contact you with relevant information and offers, or to fulfill any promotions related to that event.
• Protecting Rights and Safety: We may share your personal data with others, if we believe in good faith that this will help protect the rights, property or personal safety of Urbanmilawear, any of our Services’ visitors, customers, business or professional contacts, or any members of the general public.
• Affiliated Companies: We may share personal data internally with our affiliated companies, for the purposes described in this Privacy Policy. In addition, should Urbanmilawear or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal data may be shared with the parties involved in such event.
• Additional Disclosure: Urbanmilawear may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. Additionally, we may transfer, disclose or otherwise use non-personal data at our sole discretion and without the need for further approval.

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

5. Cookies & Tracking Technologies

• Cookies: Our Services utilise “cookies”, anonymous identifiers, pixels, container tags, and other technologies in order for us to provide our Services and ensure that they perform properly, to analyze our performance and marketing activities, and to personalise your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data (such as an IP address) previously indicated by a visitor to our Services. To learn more about our practices concerning cookies and tracking, including your ability to opt out of Targeted Advertising under relevant US State laws, or the sale or sharing of your personal information (as such concepts are defined in the CCPA), please review our Cookie Policy below.
• Google Analytics: We use Google Analytics to collect information about the use of our Services. Google Analytics collects information such as how often you visit the Services, which pages you visited when doing so, and which other sites you used prior to coming to our Services. We do not merge the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Services is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can learn more about how Google collects and processes data specifically in connection with Google Analytics here. Further information about your option to opt-out of these analytics services is available here.

6. Communications

• Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us, including by e-mail, SMS and mobile notifications) of changes or updates to our Services, billing issues, password reset notices, etc. Please note that you will not be able to opt out of receiving certain communications which are integral to the operation and use of our Services (like password resets, invoices or order updates).
• Promotional Communications: We may also notify you about new features, additional offerings, better ways to use the Services, events and special opportunities, or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., phone, SMS, mobile notifications, or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify Urbanmilawear at any time by sending an e-mail to urbanmilawear@gmail.com or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
• Friends’ Referral: We may contact you with special offers if your friend provides us with your contact information and asks us to contact you for this purpose.

7. Data Security

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

8. Your Rights

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

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

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

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

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

9. Additional Notices and Contact Details

• Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. We will make reasonable efforts to post a clear notice on our Services and/or we send you an email (to the extent that you provided us with your email address) regarding the change if we believe any substantial changes are involved. Such changes will take effect four (4) days after the notice is posted on the Services or sent via email, whichever is earlier. After such notice period, all amendments to this Privacy Policy shall be deemed accepted by you.
• External Links: While our Services may contain links or integrations to other websites, social networks or services (including your ability to share information with social platforms, to use social platforms to create your account or to connect your account with respective social platforms), we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or services of such third parties, or interact with social network integrations. We recommend you read the privacy policies of each and every website and service you visit. This Privacy Policy only applies to our Services.
• Children’s Privacy: Our Services are not intended for use by children under the age of 18. We do not knowingly collect personal data from minors under the age of 18 and do not wish to do so. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at urbanmilawear@gmail.com
• EU and UK Representatives: Urbanmilawear has designated Urbanmilawear Sp. zo.o as its representative in the European Union, and Urbanmilawear Optical Limited as its representative in the UK for data protection matters pursuant to Article 27 of the GDPR and UK GDPR. Our EU and UK representatives may be contacted only on matters related to the processing of personal data. To make such an inquiry,  send an email to urbanmilawear@gmail.com
• Contacting Us: If you have any comments or questions about this Privacy Policy or if you have any concerns regarding your personal data held with us, please contact us at urbanmilawear@gmail.com

10. Cookie Policy

Last updated: 13 December 2024

Urbanmilawear, together with our subsidiaries, affiliates, and, related companies, (“Urbanmilawear”, “our”, “we” or “us”), uses certain web monitoring and tracking technologies, such as cookies, beacons, pixels, tags, and scripts (collectively – “cookie/s”). These technologies are used to maintain, provide and improve our website and mobile application (the “Services”), to optimize our offerings and marketing activities, and to provide our visitors and users (“you”, or “your”) with a better experience.

This Cookie Policy contains information on Urbanmilawear ’ cookie practices. If you are unable to find the information you were looking for, or you have any further questions about the use of cookies on our Services, please email urbanmilawear@gmail.com

For more information about our general privacy practices, please read our Privacy Policy.

10.1 What are cookies?

Cookies are small files containing a string of characters that are stored on your computer or mobile device through the browser (for example, Google Chrome or Safari) or directly by mobile applications when you visit a website or use an app. You can think of cookies as providing a so-called memory for the website or app, enabling them to recognise you upon your return and respond in a manner tailored to your usage and preferences. Cookies can collect information and data such as your IP address, nationality, city, type of device, browser, operating system, screen resolution, browsing origin, time and duration of visit, pages visited, and the number and frequency of your visits.

Cookies may be set up for the duration of your visit (session cookies) or for longer periods (persistent cookies). The length of time a persistent cookie stays on your device varies between cookies, depending on their functionality. They may be set up by us (first-party cookies) or by third-party providers who work with us (third-party cookies). Please note that our access to and control over such third-party cookies, beyond the scope of our Services, is limited and subject to such other websites, services and providers’ own terms and policies.

You are not obligated to accept all cookies to be able to use our Services. However, enabling cookies may allow for a more personalised browsing experience and is required for most of our Services to work properly.

10.2 What cookies do we use?

Cookies, both first and third party, are typically categorised as follows:

• Strictly necessary cookies: These cookies are necessary to provide you with core website functionality such as user login and account management. The website cannot be used properly without strictly necessary cookies. Thes cookies cannot be disabled through our cookie management tools.
• Functional cookies: These cookies are employed to enhance the functionality and personalization of our Services. We use functional cookies to remember visitor information on the website (for example, language, time zone, enhanced content). Without these cookies, certain functionalities will not be available to you.
• Performance cookies: These cookies are used for gathering analytics data on how you interact with our Services so that we can improve their performance accordingly. Without these cookies, our ability to improve your user experience and that of others will be reduced.
• Targeting cookies: These cookies are used to make advertisements more relevant to you. Our advertising partners may use them to learn about your browsing habits, including your visits to our Services, the pages you have visited and the links and advertisements you have clicked on. They may also collect other unique identifiers that help identify you and your interests. This information is used to retarget you and serve advertisements that are relevant to you. For example, if you view a specific page on our Services, an advertisement for our offerings referenced on that page or similar products and services may be delivered to you on other media.

To learn more about the specific cookies we use and how we categorise them, please click the ‘Cookie Settings’ button available on the “Cookie Policy” page, which is located in our website’s footer. You can always withdraw your consent to the use of non-necessary cookies (i.e., Functional, Performance and Targeting Cookies) by re-opening the settings and modifying your selection.

10.3 How do we use cookies?

We use cookies to help our Services and online pages work more efficiently, and gain information about your interactions with our websites, app and online pages.

We use Functional and Performance Cookies in order to monitor, study and analyze the use of our Services. This helps us assess how we may improve individuals’ user experience and the overall performance of our Services, as well as explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences.

We use Targeting Cookies to facilitate and optimise our marketing campaigns, ad management and sales operations. These cookies help manage and deliver advertisements for our products and offerings more effectively, including on other websites and applications.

We may combine non-personally identifiable information collected through cookies with personal data we have about you to improve your user experience (for example, to tell us who you are or whether you already have an account with us).

We may also supplement the information we collect from you with information received from third parties. This is done to enhance our Services or offer you information that we believe may be of interest to you.

Where we use cookies to collect information that is personally identifiable or that can become personally identifiable if combined with other information, our Privacy Policy will apply in addition to this Cookie Policy.

10.4 What is the Google Analytics cookie and how is it used?

Our Services use Google Analytics, a web analysis service provided by Google Inc. (“Google”) which is based on cookie technology. The information generated by the cookies is usually sent to and stored in a Google server in the USA. On behalf of Urbanmilawear, Google will use the generated information to evaluate your use of the Services, to compile reports on website activities, and to provide Urbanmilawear, as the website operator, with additional services connected with the website and internet use. The IP address transmitted by your browser in connection with Google Analytics is not collated with other data by Google. We have also taken measures to anonymise such IP addresses and to limit its retention period by default. Further information about the privacy practices Google Analytics is available at www.google.com/policies/privacy/partners/. Further information about your option to opt out of Google Analytics is available at https://tools.google.com/dlpage/gaoptout.

10.5 How can you control cookies?

Except for Strictly Necessary Cookies, you have a right to decide whether to accept or decline cookies. Where required by applicable law, we will not set non-necessary cookies unless you enable them. When first visiting our website, you may encounter our cookie banner, which allows you to control your cookie preferences. Regardless of your location, you can change your cookie choices at any time by clicking the “Cookies Settings” available on the “Cookie Policy” page which is located in our website’s footer.

Most browsers have certain cookie control features (usually located in the ‘options’ or ‘preferences’ menu of your browser), which will allow you to handle each new cookie in a variety of ways, prevent cookies from being placed, and provide you with the ability to delete all cookies that are already on your device (each depending on your browser settings).

You can also change your mobile device settings (e.g., iPhone, iPad, Android phones) to control whether you see online interest-based ads.

Please note that any such changes may result in you having to manually adjust certain preferences every time you visit a website. Additionally, such changes may result in certain services and functionalities not working.

Finally, most advertising networks offer individuals from the US (www.aboutads.info/choices), Canada (www.youradchoices.ca/choices), EU (https://youronlinechoices.eu/) or UK (https://www.youronlinechoices.com/uk/your-ad-choices)a way to opt out from the collection of their data by advertising partners who participate in the Network Advertising Initiative (NAI), the Digital Advertising Alliance (DAA) and the European Digital Advertising Alliance (eDAA). This does not opt you out of being served advertising entirely as you will continue to receive generic advertisements.

10.6 “Do not track” signals

Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. 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, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings and our Cookie Banner as instructed above. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.