Privacy Notice - Shamir




Last Revised: April 1, 2021


Shamir Optical Industry Ltd., its subsidiaries and affiliates (“Shamir”, “Company” “we” or “us”) respects the privacy of the visitors and/or users (“User(s)” or “you”) of its website at (including its subdomains) (collectively, the “Site”) and is committed to protect the personal information that its Users share with it. We believe that you have a right to know our practices regarding the information we may collect and use when you visit and/or use our Site.


  1. Your Consent (PLEASE READ CAREFULLY!)



  1. Which information we may collect on our Users?


We may collect two types of data and information from our Users:

  1. Non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information.Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering into and/or using the Site and/or are accessing Shamir’s Services and Products. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, the activity of the User on the Site, type of operating system, User’s ‘click-stream’ or searches on the Site, the period of time spent on certain pages, type and version of browser, keyboard language, screen resolution, number of pages visited by the User etc.
  2. Personally identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed Personal Information so long as such connection or linkage exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance of the Privacy Policy.


  1. How Do We Collect Information on Our Users?

There are a few methods that we use:

  1. We collect information through your entry and use of the Site and/or Products and/or Services.In other words, when you are using the Site and/or Products and/or Services we are aware of it and may gather, collect and store the information relating to such usage.
  2. We collect information which you decide to provide us voluntarily. For example, we collect Personal Information when you contact us through the contact form or when you open an Account.
    We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.


  1. What are the Purposes of the Collection of Information?


Non-personal Information is collected in order to:

Personal Information is collected in order to: 


  1. Sharing Information with Third Parties

Shamir will not share any Personal Information it collects with any third party, other than in the following circumstances: (a) to operate the Site; (b) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (c) to enforce this Privacy Policy, including investigation of potential violations thereof; (d) to detect, prevent, or otherwise address fraud, security or technical issues; (e) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (f) to protect the rights, property, or personal safety of the Company, its Users or the general public; (g) by virtue of undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of the Company; or (h) pursuant to your explicit approval prior to the disclosure. Note, that we collect, hold and/or manage Personal Information through Shamir’s authorized third party service providers and vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction.
For avoidance of doubt, Shamir may transfer and disclose Non-personal Information to third parties at its discretion, including without limitation for statistical, analytical and research purposes and for customization, development and improvement of our Site and/or the Products and/or Services.

  1. What is our Privacy Policy with respect to your End-Users?


In order to provide you with our Products and/or Services, including Products and/or Services that are customized and tailored to the needs of your customers and in order to constantly improve our Products and/or Services, we and our authorized third-party service providers and vendors may collect and process certain data related to your customers (the “End-Users” and the “End-User Data”, respectively).

End User Data consists of the following types of information:


  1. Deletion or Modification of your Personal Information


In any event, if for any reason End-Users (or any person) wish to delete or modify Personal Information, you can do so within your Account. Otherwise, please send us an e-mail with adequate detail of your request to: and we will exercise all reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws. Note that unless otherwise explicitly specified herein and/or unless you instruct us otherwise we may retain your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, all as permitted under any applicable privacy laws.

Aggregated and/or anonymous information derived from your use of the Site or Services may remain on our servers indefinitely.

  1. Minors

The Site is intended for Users over the age of eighteen (18). Shamir does not intend and does not knowingly collect Personal Information from children under the age of thirteen (13) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of thirteen (13) are not using the Site. If we learn that we collected Personal Information from children under the age of thirteen (13) we will delete that information as quickly as possible. Please contact Shamir at if you have reasons to suspect that Shamir collected Personal Information from children under the age of thirteen (13) and will delete that information as quickly as possible. It is hereby clarified that the documents you provide us access to may include information regarding children under the age of thirteen (13) only in the event that the legal guardian of such child has agreed to such use, all as required under any applicable laws.


  1. Security

We take reasonable measures to maintain the security and integrity of our Site and/or Products and/or Services and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. The Personal Information is hosted with reputable cloud-hosting vendors which provide advanced security standards (both physical and logical). Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. SHAMIR SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.


  1. Third Party Service Providers

In order to provide the Site and/or the Products and/or Services we may be using third party service providers, who may collect, store and/or process the information detailed herein. Shamir uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and personal information. Such software and services include, without limitation, Google Analytics which privacy policy can be found at: Please read such third party service providers’ terms of use and privacy policies to understand their privacy practices Please note that we do not control such third party service providers.


  1. Links to Third Party Websites

Certain links provided herein permit our Users to leave this Site and enter non-Shamir sites or services (including but not limited to Facebook’s “Share” and “Like” buttons available in our Site, Twitter and Google+). Shamir is not responsible or liable for such linked sites and services’ privacy practices and/or any other practices. Your access to, use of and reliance upon any such sites, services and content and your dealings with such third parties are at your sole risk and expense. Those linked sites and services are provided solely as a convenience to you. Most of such linked sites and services provide legal documents, including terms of use and privacy policy, governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information they are collecting.


  1. Cookies and Other Tracking Technologies.

When you access or use the Site, we or our third party service providers may use industry-wide technologies such as “cookies” or other similar technologies which store certain information on your computer or device (“Cookies“), which will allow us to enable automatic activation of certain features and make your experience much more convenient and effortless. We or our authorized third party service providers may use both session cookies (which expire once you close the Site) and persistent cookies (which stay on your system until you delete them). It is easy to disable or delete Cookies. Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you disable or erase cookies, your online experience may be limited. Cookies usually store only a Non-personal Information, such as the web pages you have visited, the duration of your browsing, etc. Shamir does not control such third party service providers.


  1. International Data Transfer

In order to provide the Site and our Products and/or Services, we may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service providers (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.


  1. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Site and any information collected therein. Shamir reserves the right to change this policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this policy on the homepage of the Site and/or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such substantial changes will take effect seven (7) days after such notice was provided on our Site or sent by e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the above stated “Last Revised” date and your continued use of the Site after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the terms hereof should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by law and without any prior notice.


  1. Got any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to




Original Effective Date: January 1, 2020

Last Revised: April 1, 2021

This PRIVACY POLICY SUPPLEMENT FOR CALIFORNIA RESIDENTS (“Privacy Policy Supplement”) supplements the Privacy Policy Statement of Shamir Optical Industry, Ltd., and its subsidiaries (collectively, “Shamir”), “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“Consumer(s)” or “you”). This Supplement should be read in conjunction with the Privacy Policy Statement. The definitions and provisions of the Privacy Policy Statement apply to Consumers, but if there is any conflict between the Privacy Policy Statement and this Supplement with respect to a Consumer, the terms of this Supplement shall prevail. Enforcement of this Supplement shall be governed by the laws of the State of California and the courts of the State of California shall have jurisdiction.


We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), California Civil Code § 1798.100 et seq. and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Supplement.



We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or device (“Personal Information”). The following table states the categories of Personal Information from Consumers we have collected within the last twelve (12) months and may collect in the future:


A. Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (California Civil Code §1798.80(e) A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card categories listed in the number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories. YES
C. Protected classification under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender characteristics under identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a Consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment

related information

Current or past job history or performance evaluations.


J. Non-public education information (per the Family Educational Rights and Privacy Act, 20 United States Code §1232(g). 34 CFR Part 99.) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.


K. Inferences drawn from other Personal Information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.




Personal information does not include:


  1. Publicly available information from government records.


  1. De-identified or aggregated Consumer information.
  2. Information excluded from the CCPA’s scope, such as:

–Health or medical information covered by the Health Insurance Portability and                                       Accountability Act of 1996 (HIPAA) and the California Confidentiality of                                                     Medical Information Act (CMIA) or clinical trial data;


–Personal information covered by certain sector-specific privacy laws, including                                       the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or                                              California Financial Information Privacy Act (FIPA), and the Driver’s Privacy                                                Protection Act of 1994.

We obtain the categories of Personal Information listed above from the following sources:


  1. Directly and indirectly from activity on our website For                                                    example, from submissions through our website portal or website usage details                                       collected automatically.


  1. From third-parties that interact with us.




We may use or disclose the Personal Information we collect for one or more of the following business purposes:


  1. To fulfill or meet the reason for which the information is provided. For example,                                      opening an Account on the website.


  1. To provide you with information, products or services that you request from us.


  1. To provide you with email alerts, event registrations and other notices concerning                                   our products or services, or events or news, that may be of interest to you.
  2. To carry out our obligations and enforce our rights arising from any contracts                                           entered into between you and us, including for billing and collections.
  3. To improve our website and present its contents to you.


  1. For testing, research, analysis and product development.


  1. As necessary or appropriate to protect the rights, property or safety of us, our                                          business associates, or others.

8          To respond to law enforcement requests and as required by applicable law, court                                    order, or governmental regulations.


  1. As described to you when collecting your Personal Information or as otherwise                                        set forth in the CCPA.
  2. To evaluate or conduct a merger, divestiture, restructuring, reorganization,                                              dissolution, or other sale or transfer of some or all of our assets, whether as a                                          going concern or as part of bankruptcy, liquidation, or similar proceeding, in                                             which Personal Information held by us is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing by updating this notice to reflect the change.




In the preceding twelve (12) months, we have not sold any Personal Information. We will not sell any Personal Information. Should we commence sale of Personal Information, we will include an “opt-out” election as required by the CCPA and applicable Regulations.


We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter an agreement that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the agreement. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:


  1. Category A: Identifiers.


  1. Category B: Personal information categories listed in the California Customer                                           Records statute (California Civil Code §1798.80(e).


  1. Category F: Internet or other similar network activity.


  1. Category G: Geolocation data.



We disclose your Personal Information for a business purpose to the following categories of third parties:

  1. Our affiliates.


  1. Service providers.
  2. Third parties to whom you or your agents authorize us to disclose your Personal                                      Information in connection with products or services we provide to you.



The CCPA provides Consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights


You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable Consumer request, we will disclose to you:


  1. The categories of Personal Information we collected about you.
  2. The categories of sources for the Personal Information we collected about you.


  1. Our business or commercial purpose for collecting or selling that Personal                                                Information.


  1. The categories of third parties with whom we share that Personal Information.


  1. The specific pieces of Personal Information we collected about you.
  2. If we sold or disclosed your Personal Information for a business purpose, two                                           separate lists disclosing:


–Sales, identifying the Personal Information categories that each category of                                            recipient purchased; and


–Disclosures for a business purpose, identifying the Personal Information                                      categories that each category of recipient obtained.

Deletion Request Rights


You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable Consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We are not required to comply with your deletion request if retaining the information is necessary for us or our service providers to:


  1. Complete the transaction for which we collected the Personal Information,                                               provide a good or service that you requested, take actions reasonably anticipated                                    within the context of our ongoing business relationship with you, or otherwise                                         perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or                                           illegal activity, or prosecute those responsible for such activities.


  1. Debug products to identify and repair errors that impair existing intended                                                 functionality.
  2. Exercise free speech, ensure the right of another Consumer to exercise their free                                     speech rights, or exercise another right provided for by law.
  3. Comply with the California Electronic Communications Privacy Act (Cal. Penal                                           Code § 1546 seq.).


  1. Engage in public or peer-reviewed scientific, historical, or statistical research in                                        the public interest that adheres to all other applicable ethics and privacy laws,                                         when the information’s deletion may likely render impossible or seriously impair                          the research’s achievement, if you previously provided informed consent.
  2. Enable solely internal uses that are reasonably aligned with Consumer                                                       expectations based on your relationship with us.
  3. Comply with a legal obligation.
  4. Make other internal and lawful uses of that information that are compatible with                                     the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable Consumer request to us by either:


–Calling us at (877) 514-8330.

–Contacting us at


Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable Consumer request related to your Personal Information.

You may also make a verifiable Consumer request on behalf of your minor child.

You may only make a verifiable Consumer request for access or data portability twice within a 12-month period. The verifiable Consumer request must:

  1. Provide sufficient information that allows us to reasonably verify you are the                                            person about whom we collected Personal Information or an authorized                                       representative.
  2. Describe your request with sufficient detail that allows us to properly understand,                                   evaluate, and respond to it.


We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable Consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.


Response Timing and Format


We endeavor to respond to a verifiable Consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable Consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.



We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  1. Deny you goods or services.
  2. Charge you different prices or rates for goods or services, including through                                              granting discounts or other benefits, or imposing penalties.
  3. Provide you a different level or quality of goods or services.
  4. Suggest that you may receive a different price or rate for goods or services or a                                        different level or quality of goods or services.



We reserve the right to amend this privacy notice at our sole discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage. The method of notification shall be in our sole discretion.


If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:


Phone: (877) 514-8330











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