Last Updated: September 15, 2020
- Types of Personal Information We Collect and How We Collect It.
We collect personal information when you use our Services, create an account with us or submit personal information to us. Personal information is any information that relates to you, identifies you personally or could be used to identify you, such as your name, email address, phone number, address and payment account number. The types of personal information that we may collect about you include, but are not limited to:
- Information You Voluntarily Provide to Us.
- Information You Provide as Part of the “Refer a Friend” Program
- Information You Post on the Site.
- Information You Provide to Participate in Sweepstakes.
- Information Automatically Collected Through the Site.
We collect the personal information you give us when you use our Services. For example, if you are a visitor to the Site, we may collect information that you provide to us when you communicate with any of our departments such as customer service, or when you complete online forms or surveys provided on the Site. You may also choose to provide your email address to us if you would like to receive additional information about the Site and the products and services that the Company offers. If you share any sensitive information through our Services, such as information about your medical or health conditions, we will handle, process and share this information in accordance with all applicable legal and regulatory requirements.
If you want to become a registered user of the Site, access certain premium services offered through the Site or make a purchase through the Site, you will be required to provide additional information. This information will include your first and last name, mailing address, and email address. In addition, if you purchase any products through the Site, you will be asked to provide your payment account or credit card information, your eye glass prescription data and certain measurements regarding your eyes, vision, vision health, and needs for eyeglasses.
You may provide photographs, videos, and/or facial scans if you choose to use the Zenni Frame Fit™, Virtual Try-On, and Pupillary Distance (“PD”) Measurement services. These services use the shared photographs, videos, and/or facial scans to create a digital reconstruction of your face to show how you would look wearing a particular pair of glasses or to calculate a PD measurement, which is needed to make prescription eyeglass lenses.
You may provide us with the names and email addresses of your friends and contacts if you use our “Refer a Friend” program on the Site. We will only use the email address you provide for your friend or contact for the limited purpose of sending the applicable invitation, link or communication.
If you post information on public areas of the Site that information may be collected and used by Zenni, other users of the Site, and the public generally. We strongly recommend that you do not post any information through the Site that allows strangers to identify or locate you or that you otherwise do not want to share with the public.
Information we collect in connection with a Promotion will be used to administer the Promotion, such as by notifying winners and distributing prizes. As permitted by applicable law, your information may also be used by the Company or the Promotion sponsor for marketing purposes. Your entry into the Promotion may result in the addition of your information to our mailing list as well as to the mailing list of our promotional partners. Acceptance of a prize may require you (unless prohibited by law) to allow us to post publicly some of your information via the Site, such as on a winner's page.
We may automatically collect information about you when you use the Site. For example, if you access the Site through a computer, we will automatically collect information such as your browser type and version, computer and connection information, Internet Protocol (“IP”) address and standard web log information. If you access the Site through a mobile device, we may also be able to identify the location of your mobile device. You may choose not to share your location details with us by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer. Please see section 2 below to learn more about our automatic personal information processing activities.
- Information You Voluntarily Provide to Us.
- Cookies and Other Tracking Technologies.
We may automatically collect information from you when you use the Site using “cookies” and other similar technologies, such as web beacons, to automatically collect information about you when you use the Site and to personalize your experience with our Services. The Company and third -party businesses may use the information collected through the Site using cookies, web beacons, and other similar technologies to help manage online advertising programs. This information may enable us, as well as third-party advertising services and other third-party businesses to track the actions of users online over time and across different web sites or platforms to measure statistics relating to marketing efforts, and to deliver electronic advertisements that may be more relevant to individual consumers and that will improve the consumer experience.
Cookies are small amounts of data that are stored within your computer’s Internet browser and that are accessed and recorded by the websites that you visit so that they can recognize the same browser navigating online at a later time. Information that may be collected by cookies when you use the Site may include, without limitation: the pages you visit within the Site; the date and time of your visit to the Site; the amount of time you spend using the Site; the IP address used to connect your computer to the Internet; and/or your computer and connection information such as your browser type and version, operating system and platform. Generally, we use first-party and third-party cookies for the following purposes: to make our Services function properly; to provide a secure browsing experience during your use of our Services; to collect passive information about your use of our Services; to measure how you interact with our marketing campaigns; to help us improve our Services; and to remember your preferences for your convenience.
- Strictly Necessary Cookies. These cookies are essential because they enable you to use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled.
- Functional Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.
- Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.
- Behavioral Remarketing.
- Other Tracking Technologies.
- Your Choices
We may use third-party service providers to monitor and analyze the use of our Site. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.
To see how successfully our marketing campaigns or other Site goals are performing we sometimes use conversion pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page (e.g. a thank you page once you have completed the procedure for subscribing to one of our services or have completed one of our forms). We also use web pixels to analyze usage patterns on our Site. The use of a pixel allows Zenni to record that a particular device, browser, or application has visited a particular webpage.
Pages of our Site may also use Java scripts, which are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components; entity tags, which are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and HTML5 local storage, which allows data from websites to be stored or “cached” within your browser to store and retrieve data in HTML5 pages when the website is revisited.
Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Sites by taking the steps outlined below.
- First-Party Cookies. You can set your browser to reject cookies or to notify you when you are sent a cookie. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). However, if you disable cookies you may not be able to log in to the Site or to use certain features of the Site. To find out more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.networkadvertising.org/managing/opt_out.asp.
- Mobile Advertising. You can opt out of having your mobile advertising identifiers used for certain types of advertising by accessing the settings in mobile device and following the instructions. If you opt-out, we will remove all data about you and will not collect any further data. The random ID previously assigned to you will be removed. Thus, if at a later stage, you decide to opt-in, we will be unable to continue and track you using the prior ID and you will for all practical purposes be a new user.
- Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to http://www.aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://optout.aboutads.info/) or the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1). In addition, on your iPhone, iPad or Android mobile device, you can change your device settings to control whether you see online interest-based ads.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here:
- Google Chrome
- Internet Explorer
- Mozilla Firefox
- Safari (Desktop)
- Safari (Mobile)
- Android Browser
- Opera Mobile
Your browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. However, since uniform standards for “DNT" signals have not been adopted, we do not disable tracking technology that may be active on the Site in response to any “do not track” requests that we receive from your browser.
- To Fulfill Orders and To Provide You Our Services.
- For Internal Use.
- Marketing Communications.
- To Enforce Compliance with Our Terms and Agreements or Policies.
- To Ensure the Security of the Services.
- To Maintain Legal and Regulatory Compliance.
We use personal information we gather through the Site to process your orders or respond to requests or communications. When placing on order for glasses through the Site, you will have the ability to opt-in to receive “Renewal Reminders” from us. If you opt-in to receive Renewal Reminders, we will use the email address you have provided to us to send you reminders that your prescription (Rx) may require renewal.If you choose to use our Virtual Try-On and/or PD Measurement services, we use the photographs, videos, and or facial scans you provide through the Services to create a digital reconstruction of your face. With this reconstruction, we can show you how a pair of glasses would look on your face with the Virtual Try-On tool. Similarly, with the PD Measurement tool, we can determine your pupillary distance, which is needed to produce prescription eyeglass lenses.
We may use personal information we collect about you through the Site to help us better understand how the Site and our products and services are being used. By identifying patterns and trends in usage, we are able to better design the Site and our products and services to improve your experience.
If you have provided your email address to us, we may email you about products and services that we believe may be of interest to you. If you wish to opt-out of receiving these emails from us, please follow the instructions contained in each email you receive from us which will allow you to opt-out of receiving further email marketing communications from us.
We care about keeping you secure and safe while using our Services. Keeping you safe requires us to process your personal information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information. We cannot ensure the security of our Services if we do not process your personal information for security purposes.
Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, ensure compliance with employment and recruitment laws or as necessary to manage risk as required under applicable law. Without processing your personal information for such purposes, we cannot perform the Services in accordance with our legal and regulatory requirements.
We may share your personal information as described below:
- Service Providers.
- Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies.
- Business Transfers; Bankruptcy.
- Our Affiliates.
- Marketing Partners.
- Aggregate Information
We will disclose your personal information to our contractors, affiliates, distributors and suppliers (“Service Providers”) who provide certain services to us or on our behalf, such as fulfilling orders you place through the Site, processing payments, operating and supporting the Site, including the Zenni Frame Fit™ service, analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the information needed to perform these limited functions on our behalf.
We will disclose personal information to government authorities or third parties if: (a) required to do so by law, or in response to a subpoena or court order; (b) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or (c) we believe that you have abused the Site by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.
We may share some or all of your personal information with our parent company, subsidiaries and corporate affiliates, joint ventures, or other companies under common control with us. If you opt-in to receive marketing communications from third parties, we may permit these entities to use your information for their own marketing purposes. If you would like us to stop providing your information to our affiliates for their own marketing purposes, you may opt-out by emailing us at firstname.lastname@example.org.
If you affirmatively opt-in to receive marketing communications from third parties, we may, from time to time, share personal information you provide to us with selected third-party marketing partners that we believe offer products or services that may be of interest to you. If you would like us to stop providing your information to our third-party marketing partners, you may opt-out by emailing us at email@example.com.
We may share information relating to users of the Site with affiliated or unaffiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.
- Social Media Services.
- Third-Party Review Services.
- Payment Processors.
- Third-Party Promotions.
The Site may include links to social media services or their features, such as sharing buttons, that will enable you to post comments, stories, reviews or other information on applicable social media websites. Your use of these social media services may result in the collection or sharing of your personal information by these social media services. We encourage you to review the privacy policies and settings on the social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those social media services.
All payments made through the Site are processed by our third-party providers. All information collected by these third-party providers for purposes of processing your payments is not available to us, unless you have otherwise provided this information to us in connection with your use of the Site.
As described below, we provide you with the ability to access, correct and delete your personal information.
- Right of Access and Right of Correction.
- Right of Deletion.
If you have created a user account through the Site, you will have the ability to access, update and correct personal information you have provided in connection with your account by logging into your account through the Site.
If you would like to delete your Zenni account, please contact us via email at firstname.lastname@example.org. Please be aware that even after your Account is terminated or deleted some or all of your information may still remain visible to others, including but not limited to any information that has been: (a) incorporated into others user's content, comments, posting, and submissions, including but not limited to Course comments; (b) copied, stored or disseminated by other users; (c) shared or disseminated by you or others such as in a public posting; or (4) posted on a third party platform. Termination of your account will not result in the removal of information collected and already put in aggregate form or information that cannot, in our sole discretion, be removed without undue burden to us.
We implement security measures intended to protect against the loss, misuse and alteration of the personal information under our control. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, the Company cannot guarantee or warrant the security of any information you transmit on or through the Site and you do so at your own risk. Still, the security of your personal information is important to us. When you enter sensitive information on our site, we encrypt the transmission of that information using secure socket layer technology (SSL).
Please remember that you play a valuable part in security as well. Your password to access our Site, which you select at registration, should never be shared with anyone and should be changed frequently. After you have finished using our Site, you should log off and exit your browser so no unauthorized persons can use our Site with your name and account information.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary for the last twelve (12) months of the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect the Personal Information, where we obtain the Personal Information, and the third parties that we may share the Personal Information. We generally collect the following categories of Personal Information when you use our Services:
- Identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices;
- Commercial information such as records of products or services purchased, obtained, or considered by you;
- Internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
- Your geolocation, to the extent you have configured your device to permit us to collect such information;
- audio recordings of your voice to the extent you call us, as permitted under applicable law; and Inferences about your preferences, characteristics, behavior and attitudes.
We generally do not collect protected classifications about our users, biometric information, professional or employment-related information, or education-related information. For more information about the Personal Information we collect and how we collect it, please refer to sections 1 and 2 above.
We collect your Personal Information for the business purposes described in sections 2 and 3, above. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or another operational purpose that is compatible with the context in which the personal information was collected.
The categories of third parties with whom we may share your Personal Information are listed in Sections 2, 4 and 5 above.
If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of our network systems.
To assert your right to know, your right to access, or your right to delete your Personal Information, please contact us by email at email@example.com. To confirm your identity, we may ask you to verify Personal Information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
- Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, access, delete or opt-out of sales.
- Right to Know. You have the right to request in writing: (i) a list of the categories of Personal Information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties' direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, you have the right to request: (i) the categories of Personal Information we have collected about you, (ii) the categories of sources from which Personal Information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared Personal Information, and (v) the specific pieces of Personal Information we hold about an individual.
- Right to Access. You have the right to request a copy of the specific Personal Information we collected about you during the 12 months before your request.
- Right to Delete. You have the right to request us delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions.
- Right to Opt-Out of Selling. The CCPA broadly defines “Personal Information” and “selling” such that sharing identifiers linked to you for a benefit may be considered a sale. We do not “sell” your Personal Information in the traditional sense; however as described above, we may share information about you with our partners, third parties or affiliates for our marketing purposes. Under the CCPA, such sharing may be considered a “sale” of Personal Information. All California residents have the right to opt-out of such sharing. For more information about how you can opt-out of having your information shared in this way, please click on the “Do Not Sell My Personal Information” link in the footer, which can be found under the section entitled “About Zenni Optical”. Please note that if you opt-out, we may be unable to offer you some of our Services which require sharing of Personal Information.