Updated Oct 23 2018
“Personal Information” means any information that is about an identifiable individual. This includes information that directly identifies an individual or information that could reasonably be connected to an individual. This includes a first and last name, home or other physical address, an email address, phone number or other contact information, whether at work or at home.
“Product” means any hardware products manufactured or sold by the Company, and includes the software running on the device, any the software running on your mobile device device and any accessories you use with them.
We will make reasonable efforts to clearly communicate to you what personal information we collect and for what purposes.
LIMITING USE, DISCLOSURE AND RETENTION
Our collection of Personal Information is limited to what is reasonable under the circumstances, and your information will be used for the purpose for which it was collected, or when it is required or permitted by law. We may inform you about products and services by mail, e-mail, text message, telephone, or other means. If you do not wish to receive direct marketing, contact us and tell us that you do not wish to be contacted in a particular manner.
WHAT INFORMATION WE COLLECT AND WHY
Our Focals™ Product
The use of the Focals™ product involves the collection, use, processing and disclosure of certain kinds of personal information. In order to use the Focals™ product, you have to create an account with the Company. This involves providing your name, email address and a password to keep your account secure. We also collect information about how you use the Focals™ product and how it performs for you so that we can understand how users use the product, to improve the product and to help you with any issues that you may have with the product.
Each Focals™ product is custom made or sized for the user, and is then delivered to the user. This requires us to collect information about the wearer’s head and eyes, which we do using precision scanning equipment. This information is then used to custom manufacture the Focals™ product for you and to assist us in developing our products. If you use prescription lenses, we collect information about your prescription in order to manufacture the lenses for your Focals™ product.
The use of certain features on the Focals™ product involves the collection and processing of other personal information. The use of location-based services, such as directions or weather, requires the collection and use of the location of your device, which is associated with your user account and your unique Device ID. The use of communications services, such as SMS and other forms of messaging, involves the collection of your identifying information, information about the destination of the message and the message content.
When you visit our website, our website servers automatically receive and record information their logs, including the details of your browser, including your IP address, cookie information and the page you request. We use this information to manage and maintain our website and to understand how visitors use the website. This can be used to improve the website and expand the range of functions available through it.
You may voluntarily provide Personal Information to the Company through the website. For example, you may use our customer service functions which will require you to provide your contact information so that we can communicate with you.
THIRD-PARTY SERVICE PROVIDERS
We employ other companies and individuals to perform functions on our behalf. Examples include software publishers that have specialized products that support the features and functions of the Company’s Products.
Unless otherwise indicated, our service providers who have access to Personal Information are given such access only to the extent needed to perform their functions on our behalf, but may not use it for other purposes. By providing your Personal Information to the Company in order to obtain the Products or services, you acknowledge and agree that transfer of your Personal Information to such third parties may be necessary to provide you with such products and services, and you hereby consent to such disclosure.
For example, the Focals™ product incorporates software from, and interacts with, Foursquare Labs, Inc. in order for Focals™ product to provide certain location services and exchange data with Foursquare. Foursquare may collect and use information that does not personally identify you, such as your device type, advertising identifier on your device and device usage information (for example, a date/time stamp and your location when the App communicates with Foursquare).
Third party services and advertising
SHARING AND DISCLOSURE INFORMATION
SECURITY OF INFORMATION
The Company will take reasonable, industry standard precautions to maintain the confidentiality and security of your Personal Information so that it is not disclosed to anyone outside our group of companies and our selected third party service providers/business partners without your consent, unless required by law or as otherwise set forth herein. Where possible, the Company Labs protects the security of your information during transmission by using Secure Sockets Layer (SSL) and Transport Layer Security (TLS) software, which encrypts the information.
Personal information collected by the Company may be stored and processed in Canada, the United States or any other country in which the Company or its affiliates, subsidiaries, service providers or agents maintain facilities, and by using the website or the Company’s Products, you consent to any such transfer of information outside of your country.
MAINTENANCE OF PERSONAL INFORMATION
The Company has established the following practices regarding the maintenance of your personal information.
If, for any reason, you wish to review your personal information that the Company has in its possession, you can contact our Privacy Officer, who will be pleased to provide you with all your personal information that the Company has on file.
Sometimes, it will be necessary for you to update your personal information the Company has on file in order to maintain accuracy. For example, if you move or change credit cards, you may be required to update your information in order to keep receiving the products and services provided by the Company. If you wish to make any changes or corrections to your personal information, please contact our Privacy Officer who will implement the changes. This will help us ensure our records are always up-to-date.
A situation may arise where you desire to have all of your personal information that is contained in the Company’s records deleted or destroyed. If this is what you wish, please contact our Privacy Officer, who will take care of removing your personal information from all of the Company’s active records. However, there may be situations where we are obligated to retain one archival copy of your information to allow us to comply with laws or respond to legal processes, and there may be instances where we are unable to remove your specific information from our records for technical reasons. We will inform you of all such situations, and will only use your retained personal information to the limited extent necessary to comply with such laws or respond to legal processes.
USE OF DE-IDENTIFIED DATA
The Company may use information that is derived from Personal Information, but has been de-identified, for for any purpose and as permitted by law. These purposes can include understanding how users use Products, our website, any aspect of our services and to develop new products and services.
CONDITIONS OF USE, NOTICES, AND REVISIONS
If you have any concern about our privacy practices, please contact us with a thorough description and we will try to resolve it.
North Inc. 24 Charles St West Kitchener, ON N2G 1H2 Canada firstname.lastname@example.org