6 Over 6 Vision Ltd. and its affiliates (“6over6“, “we”, “us”, or “our”) are on a mission to democratize access to vision care and help the whole world see clearly, by utilizing our suite of mobile optometry tools to measure the required optical parameters of their glasses or eyesight.
Generally, we process the following categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data”):
- User Data: Personal Data related our Users, mainly consisting of details provided voluntarily by our Users when creating an account with Services (“Contact Data”), Personal Data received from our Users when using our Services’ measuring tools (“Optical Data”), as well as technical data relating to their use of the Services (“Usage Data”), as further detailed in Section 1.1. below. We use User Data for the limited purposes described in Sections 2.1. and 2.2. below.
- Partner Data: Personal Data relating to our Partners, with whom we engage in order to provide our Services to our Users. Such Partner Data mainly consisting of our Partners’ contact details collected by us when engaging with the respective Partner (“Business Contact Data”), and otherwise Personal Data provided by our Partners to us in the course of our engagement, Personal Data included in the agreements we have with our Partners, or otherwise included in any communication with them, as further detailed in Section 1.2. below. We use Partner Data for the purposes listed in Section 2.2. below.
- CRM & Prospect Data: Personal Data relating to Visitors, Users, Partners, participants at our events, and any other prospective customer, user or partner (collectively, “Prospects”) who visits or interacts with our Services, including our online ads and content, emails or communications under our control. CRM & Prospect Data mainly consisting of technical data automatically collected about our Prospect when interacting with our Services, and their contact details, as further described in Section 1.3. below. We use CRM & Prospect Data for our business interests and needs, such as improving our Services, communicating Prospects, for marketing and advertising purposes, and as further described in Sections 2.1. and 2.2. below.
You are not legally required to provide us with any Personal Data (defined below) and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your data, or to have it processed by us or any of our services providers, please simply do not enter or interact with our Sites, nor use our Services. You may also choose not to provide us with “optional” Personal Data (when applicable), but please keep in mind that without it we may not be able to provide you with the full range of our Services or with the best user experience when using our Services.
1. Data Collection & Processing
We may collect Personal Data regarding our Users, Visitors and Prospects. Such data is typically collected and generated through your interaction with our Services, through automatic means, directly from you, or other third parties.
Specifically, we collect the following categories of Personal Data:
1.1. User Data
We collect and Process the following types of User Data –
- Usage Data. When you use our Services, we will automatically collect or generate certain technical data about you. We collect our generate Usage Data either independently or with the help of third-party services (as detailed in Section 5 below), including through the use of “cookies” and other data collection technologies (as further explained in section 6 below). Such Usage Data mainly consist of connectivity, technical, and aggregated information such as IP addresses, non-identifying data regarding a device (such as type and screen resolution), operating system, various apps usage statistics, browser version, locale and language settings used, general User location by country, data and time stamp, analytics, and the pixels installed or utilized on our User’s device.
- Contact Data. Personal Data which you provide us such as your first and last name, date of birth, address, email, and other contact details, as well as any other Personal Data you choose to provide when you create an account with our Services or contact us.
Optical Data. Our Services enable Users to measure the refraction error of their eyes (GoEyes only), find their pupillary distance and the lens power of their glasses. This is done by using tools implemented in our Apps. For these purposes, Users may be asked to provide us additional Personal Data such as their mobile phone number (only as part of the download process of App, and without retaining such number once the App is installed); glasses parameters; lens analysis and pupillary distance; depth data (which is required to measure eyes’ distance and head angle in real-time by the GoEyes tool only); frontal facial pictures (which are cropped and anonymised immediately thereafter); and a "Calibration Image" (which is an image with a known size such as plastic standard magnetic card to set as a reference object). For more information about our different Services, please refer to our Site at www.6over6.com. Please note that when you are using our Services, we may ask you to present a magnetic card in order to facilitate the service. Once this is identified in the image, we make reasonable efforts to apply an obfuscation process, so to avoid saving any recognizable details that may exist on the card itself on our systems. This Calibration Image will not be linked to any Personal Data.
1.2. Partner Data
We collect and Process the following types of Partner Data –
- Contact Details. When we engage with our Partners, we collect certain Personal Data such as names of our Partners’ contact persons, their business emails, and otherwise Personal Data our Partners may provide us during our engagement.
- Business Data. We may also collect Personal Data included in agreement we have with our Partners, such as names, business email addresses, and signatures, as well as data included in communications we have with our Partners.
1.3. CRM & Prospect Data
We collect and Process the following types of CRM & Prospect Data –
- Usage Data. When you visit or interact with our Services, we will automatically collect or generate technical Personal Data about you. We collect or generate such Usage Data either independently or with the help of third-party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below). Such Usage Data mainly consists of connectivity, technical and aggregated information, such as IP addresses, non-identifying data regarding a device (such as type, screen resolution), operating system, various apps usage statistics, browser version, locale and language settings used, general Visitor location (country), date and time stamp, types of advertisements viewed and click data, and otherwise data collected by Cookies and other Data Collection Technologies, as further explained in Section 6 below.
- Prospect Information. We collect certain types of Personal Data about our Prospects, such as contact, professional and business details, and our communications with them. We may collect such Prospect Information automatically by using Data Collection Technologies (as further described in Section 6 below), when our Prospects participate at our events, or otherwise interact with our Site or Services, including our online ads and content, emails or communications under our control.
2. Data Uses
We use Personal Data as necessary for the performance of our Services (“Performance of Contract”); to comply with our legal and contractual obligations (“Legal Obligation”); and to support our legitimate interests in maintaining and improving our Services and offerings, e.g., in understanding how our Services are used, in how our campaigns are performing, and gaining insight which help us dedicate our resources and efforts more efficiently; in marketing, advertising, and selling our Services, in optimizing our marketing and advertising services, providing customer service and support operations, and protecting and securing our Users, Partners, Prospects, ourselves and our Services (“Legitimate Interests”).
Specifically, we use Personal Data for the following purposes (and in reliance on the legal bases for Processing noted next to them, as appropriate):
2.1 We Process User, Partner, and CRM & Prospect Data –
- To facilitate, operate, and provide our Services (Performance of Contract; Legitimate Interest);
- To gain a better understanding on how individuals use and interact with our Services, and how we can improve their and others’ user experience and the value they can generate from using the Services, so we could continue improving our products, offerings, and the overall performance of our Services (Legitimate Interests);
- To contact our Partners, Users, Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (Performance of Contract; Legitimate Interests; Consent);
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error, or any illegal, criminal, or prohibited activity (Performance of Contract; Legitimate Interests; Legal Obligation);
- To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we use to improve our Services, or for any other purpose (Legitimate Interests);
- To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws; regulations and standards (Performance of Contract; Legitimate Interest; Legal Obligation); and
- For any other lawful purpose, or other purpose that you consent to (Legal Obligation; Consent).
2.2 In addition, we Process User and CRM & Prospect Data also for the following purposes –
- To obtain the distance between the User’s eyes and to measure the refractive error (Performance of Contract, Legitimate Interests);
- To provide our Users and Visitors with assistance and support, to test and monitor the Services, or diagnose or fix technology problems (Performance of Contract; Legitimate Interests);
- To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localization and personalization capabilities (Performance of Contract; Legitimate Interests);
- To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioural, and interests-based advertising based on your activity, preferences, or other data available to us or to our business partners (Legitimate Interests; Consent); and
- To facilitate, sponsor, and offer certain events, contests, and promotions (Legitimate Interests).
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
3. Data Location
Your Personal Data may be maintained, processed and stored by 6over6, our authorized affiliates and Service Providers (defined below) in the United States of America, the EU and other jurisdictions, as necessary for the proper delivery of our Services, for support and maintenance, or as may be required by law.
6over6’s authorized employees may have access to the Data stored in the EU for the purposes of support and maintenance from within the EU and/or from Israel, which is a jurisdiction considered by the European Commission to offer an adequate level of protection for the personal data of EU Member State residents.
4. Data Retention
Data Retention: We retain Users’ Personal Data for as long as a session has not been completed, and we have not been notified otherwise, or as long as we consider necessary for the purposes described herein.
We keep Visitors’ Personal Data for as long as reasonably necessary in order to maintain and expand our relationship and to provide them with our Services.
We will also retain your (User) Personal Data for as long as is required 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), in accordance with our data retention policy.
Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete 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 at firstname.lastname@example.org.
5. Data Sharing
Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers: We may engage selected Third Party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, user engagement services, e-mail distribution and monitoring services, and our business, legal and financial advisors) (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.
Business Transactions: We may share your eye glasses parameters or PD and other unique identifiers with an approved business associate only for the purpose of allowing you to make business transactions upon your request (e.g. transferring your eye glasses parameters (using a standard SSL and HTTPS protocols) to an online retailer selected by you, for you to be able to purchase glasses); such data may then be retained with such party, who will become the Data Controller (as further explained in Section 10 below).
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 6over6, any of our Users or any members of the general public.
6over6 Subsidiaries and Affiliated Companies: We may share Personal Data internally within our group for the purposes described in this Privacy Notice. In addition, should we or any of our subsidiaries or 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. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.
For the avoidance of doubt, 6over6 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. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
6. Cookies and Data Collection Technologies
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.
We use Persistent Cookies within our Sites to remember your log-in details and make it easier for you to log-in the next time you access them. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Sites’ features and tools.
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, most browsers allow you to control cookies, including whether or not to accept them and to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.
Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, reports, service changes, etc. We may also send you notifications, messages and other updates. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.
Notifications and Promotional Communications: We may send you notifications concerning messages and other updates in your account. We may also send you notifications about new features, offerings, events and special opportunities or any other information we think our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, push 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 us at any time by sending an e-mail to email@example.com, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
8. Data Security
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption as appropriate and at least to the extent of applicable laws and regulations. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any Third Parties as described in Section 4 above.
9. Data Subject Rights
If you wish to exercise your rights under any applicable law, including GDPR and CCPA, to request access to, and rectification or erasure of your Personal Data held with 6over6, or to restrict or object to such Personal Data’s processing, or to port such Personal Data or the right to equal services and prices (each to the extent available to you under the laws which apply to you– please contact us by email at firstname.lastname@example.org.
Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will then be retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 3 above.
Please also note that some of the rights mentioned above, may be limited or formulated differently depending on your jurisdiction but their core is similar
10. Children’s Privacy
Our Services are not designed to attract children under the age of 16. We do not knowingly collect Personal Data from minors under the age of 16 and do not wish to do so. Our Services are capable of measuring pupillary distance from the age of 6. However, the use of such feature can only be accessed by an adult through their device on behalf of their child (or by an adult who is the legal guardian of the child). If we learn that a person under the age of 16 (or less – depending on the jurisdiction) is using the Services without parental supervision and consent where appropriate, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at email@example.com.
11. Our Role as a Data Controller/Processor
Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (or under the CCPA the “business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA the “service provider”), who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
6over6 is the “Data Controller” of User Data, Partner Data and CRM & Prospect Data, and with respect to which, assumes the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Policy.
- If any of our Users instruct us to transfer their data to any of our Partners, such as an online retailer to buy glasses from based on such data.
- If any of our customers, Partners or Users submits any Personal Data concerning their own users (for example, Users of a service or mobile app operated by our Partner, which utilizes 6over6’s technologies), or otherwise has any of their Users submit or upload Personal Data in connection with our Services.
If you are a User of any of our partners' services, please note that 6over6 only processes your data solely on their behalf. Accordingly, if you would like to make any requests or queries regarding Personal Data we process on our partner’s behalf, please contact such partner directly.
For example, if you wish to access, correct, or delete data processed by 6over6 on behalf of a partner, please direct your request to the relevant partner (who is the “Data Controller” of such data).
Should we receive such requests directly, we may refer them to our partner.
12. Additional Notices
Updates and Amendments: We may update and amend this Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is so published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.
External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or application of such third parties and to read the privacy policies of each and every website and service you visit. This Policy applies only to our Services.
PRIGHTER has been designated as 6over6’s representative in the European Union and the UK for data protection matters pursuant to the GDPR or UK GDPR, as applicable. PRIGHTER may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please send an email to firstname.lastname@example.org or visit https://prighter.com/q/15084591.
If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.