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Copy of Privacy Policy

PRIVACY NOTICE

Last modified: 2021

Under this Privacy Notice, we, Artgri Group International Pte Ltd (“Artgri”), inform you what personal data of yours we collect, why we collect, use, disclose and process it, including on our website accessible at eu.boloneyewear.com (“Website”). Your personal data means any data, whether true or not, about an individual who can be identified: (a) from that data ; or (b) from that data and other information to which the organisation has or is likely to have access. Please take the time to read this Privacy Notice carefully, it is very important that you fully understand how we are processing your personal data and how we are protecting your privacy.

DEFINITION AND CONTROLLERSHIP

Artgri is a company incorporated in Singapore, and is an authorised supplier and retailer of Bolon sunglasses and eyeglasses. Artgri shall be considered for the present Notice and the defined Processing as the Controller which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data. As A Company based in SINGAPORE Artgri appointed in the European Union an official Representative: Manuel Angiolini that can be contacted through hello@boloneyewear.com

Data Processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Personal Data means any information relating to an identified or identifiable natural person (“your personal data”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location Data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

WHAT PERSONAL DATA WE COLLECT The provision of your personal data is a requirement necessary to access our digital services (i.e. our e-commerce store), create an account to purchase our products, make payment for your products, process your orders on our end, and for us to deliver your order to you. Provision of your personal data may also be required when you make an enquiry with us.We will only be able to collect your personal data if you voluntarily submit the information to us. If you choose not to submit your personal data to us or subsequently withdraw your consent to our use of your personal information, we may not be able to provide you with some of our services. You may access, update your personal data submitted to us or withdraw your consent at any time by contacting us at hello@boloneyewear.com

We thank you for providing us with complete and accurate data, and please do inform us if your data needs to be updated. If you do not provide us with complete and accurate data, or if you do not inform us that your data needs to be updated, we may not be able to provide you with the services described in our Website.

We may collect the following categories of your personal data:• First name and last name • Title • Profession • Gender • Age – Date of birth • Payment information such as credit card and bank details • Contact information (e.g. address, email, contact number, address) • Country of residence or nationality • Products you use • Personal interests and preferences

Please be informed that we may obtain your personal data from third parties who have been duly authorised to disclose your personal data to us.

HOW WE USE PERSONAL DATA WE COLLECT We only use your personal data within the limits authorized by the laws and regulations. Sometimes, we use your personal data because the laws and regulations require us to do so. In any case, we do not make any automated decisions solely on automatic processing which may produce legal consequences concerning you, or which may significantly affect you.

We use your personal data for the following purposes (the “Purposes”): 1. For processing your orders 2. For shipping and delivering your orders to you 3. For web analytics and to improve our Website 4. For contests, newsletters and other subscriptions, online applications 5. For managing enquiries, whether or not they pertain to the supply of products by us; 6. For contact purposes and in contact forms 7. For the use of our digital services (e.g. online platform, authentication, subscribing to/unsubscribing from newsletters, for the use of applications) 8. For processing, administering and/or managing your relationship with us; 9. For conducting online operations such as sending emails (promotional, delivery updates), targeted advertising campaigns, analysis of purchase behaviour (repeated purchases, gold tiers, minimum spend etc) and coordinate fulfilment with our EU partner. 10. For statistics analysis purposes, after anonymization of the data.

The legal basis on which we ground the processing of Personal Data: • 1. Your consent: for example to send out our newsletters • 2. A contract that you have concluded with Artgri Group International Pte Ltd • 3. A legitimate interest of Artgri Group International Pte Ltd after in-depth and thoughtful analysis on the question of whether your fundamental rights and freedoms prevail • 4. Legal obligations (eg accountancy, compulsory identification of card users…)

HOW LONG WE KEEP PERSONAL DATA WE COLLECT The retention periods for your personal data depend on the purpose for which we collect this data is processed for. Even if we are not able to outline the various retention periods in a reasonably intelligible format under this notice, we want you to know that we will retain your personal data only for as long as (i) necessary for the respective purpose, (ii) necessary to carry out each of the Purposes, (iii) you have consented to, and/or (iv) required by applicable laws. Without prejudice to the foregoing, for personal data collected for the processing your orders, for example your name, address, telephone number, etc, we generally retain such data for 5 – 7 years. For personal data collected in connection with your making payment for orders, for example, your credit card number and credit card expiry date, we generally retain such data for 15 months from debit date.

PERSONAL DATA WE SHARE Please be informed that we may share your personal data with: • Others companies of the Essilor Group, which may or may not be located in Europe; and • Companies, organizations, public authorities or individuals outside of the Essilor Group (such as Facebook, Mailchimp hosting providers, IT providers, market and analyst service providers, credit agencies in order to run a credit check on orders, database management and maintenance services).

Some of these recipients of the data may be located overseas. Where applicable data protection laws for such countries deems that the level of data protection in such countries is not comparable with the level of data protection in the European Union, we will ensure that personal data be transferred outside of the county only in accordance with the requirements prescribed under the applicable data protection laws, to ensure that a standard of protection that is comparable to the protection under such laws is provided to the personal data so transferred.

For recipients located in United States, the European Commission has adopted on July 12, 2016 a Decision (the “adequacy decision”) in which it found that the E.U.-U.S. Privacy Shield ensures an adequate level of protection for personal data that has been transferred from the EU to organisations in the US. This framework protects the fundamental rights of anyone in the EU whose personal data is transferred to the US for commercial purposes.

Please also note that we use Shopify to power our online store, and your personal data will be processed by Shopify. Shopify may also share the personal data you submit on the Shopify platform with other third parties they engage with in order to provide services to you, including transaction processing and fraud prevention. The following are third parties Shopify may share your personal information with and where they are located: [Shopify Data Processing Inc. (USA), Shopify Inc. (USA) and Shopify Commerce Singapore Ptd.Ltd]. You may refer to Shopify’s privacy policy, available at https://www.shopify.com/legal/privacy on how Shopify deals with your personal data. By providing personal data on our online store, you signify your consent not just to our privacy notice, but also to Shopify’s, with regard to your personal data.

HOW WE PROTECT PERSONAL DATA We have measures in place to protect your personal data against unauthorized access, use, or disclosure, including without limitation: • We implement and maintain sophisticated technical measures to ensure that your personal data is recorded and processed in complete confidentiality and security. • We implement and maintain appropriate restrictions on access to your personal data, and monitoring of the access, use, and transfer of personal data. • All of our employees who have access to your personal data are required to enter into non-disclosure or similar agreements, which imposes obligations on them to comply with our data privacy and confidentiality requirements. • We require any business partners and third party service providers with whom we may share your personal data to comply with any applicable data privacy and confidentiality requirements. • We provide data privacy training on a regular basis to our employees and third parties who have access to personal data.

Though Essilor will take reasonable measures to protect the personal data, no method of transmission over the internet or method of electronic storage is completely secure.

WHAT RIGHTS YOU HAVE Under applicable data protection laws and regulations, you have a right: • Of access to, rectification of, and/or erasure (where required by law) of your personal data; • To restrict or object to its processing; • To tell us that you do not wish to receive marketing information; • In some circumstances, to require certain parts of your personal data to be transferred to you or a third party; and • To the extent our processing of your personal data is based upon your consent, to withdraw your consent, without affecting the lawfulness of our processing based on your consent before its withdrawal. We are committed to enable you exercising your rights: to do so, you can contact us at hello@boloneyewear.com. Please provide us with the following information, so that we can take your request with all due consideration: • Your name and surname, and a photocopy of document to justify your identity; • Your specific request (description of the rights you wish to exercise); and • The date of the application and your signature (if you sent your application by postal mail). If you do not get satisfaction by contacting us, you can also lodge a complaint about our processing of your Personal Data with a data protection authority.

DATA WE COLLECT WHEN YOU VISIT OUR WEBSITE When you access our Website, we automatically collect and store some of your data in our server logs and in cookies, which are small files we send to your computer when you visit our website. This data does not allow us to identify you directly. However, we do record data related to your browsing on our website, such as the pages that you accessed, the date and time you accessed these pages, your search queries, information on your device (hardware model, operating system version, unique device identifier, Internet protocol address, hardware settings, browser type and browser language), the date and time of your request and referral URL.

The provision of your personal data is not required if you only want to visit our Website. This means that you may refuse to accept cookies by configuring your web browser accordingly (for more information, refer to the ‘help’ section of your web browser). However, refusing cookies is likely to disrupt your navigation on our website, in particular by preventing you from accessing certain parts of it.

CHANGES TO THIS PRIVACY NOTICE We regularly review our Privacy Notice, in particular to make it compliant with new laws and regulations regarding data protection. The continued use of our Website and services constitutes acknowledge and acceptance of such revised terms to this Privacy Notice from time to time.

CONTACT If you have any question regarding our use of your personal data, you can of course contact us as set out below: Our contact details are: Artgri Group International Pte Ltd, hello@boloneyewear.com