Shanghai NVG Optics Co., Ltd. (hereinafter referred to as "we/us", Unified Social Credit Code: 913101046762928082) understands the importance of personal information to you and is committed to protecting your personal information in accordance with relevant laws and regulations, following the principles of lawfulness, legitimacy, necessity, and integrity.

This Personal Information Protection Policy (hereinafter referred to as "this Policy") applies to the products and/or services provided by the 2.5NVG website (i.e., 25nvg.zohocommerce.com, hereinafter referred to as "this Application") operated by us, as well as new service formats that may emerge with future technological developments (collectively, the "Services").

Please read this Policy carefully before using our Services and start using them only after you have confirmed that you fully understand and agree to it. Provisions involving exemptions or limitations of liability may be highlighted in bold to draw your attention. This Policy is not intended to obtain your blanket consent, but rather to obtain consent specifically for the personal information processing requirements involved in the functional scenarios you choose to use.

This Policy will help you understand the following:

1.  What Personal Information We Collect and How We Use It

2.  How We Share, Transfer, and Publicly Disclose Your Personal Information

3.  How We Protect Your Personal Information

4.  Your Rights

5.  How We Handle Children's Personal Information

6.  How Your Personal Information is Stored and Transferred Globally

7.  How This Policy is Updated

8.  How to Contact Us

1. What Personal Information We Collect and How We Use It

1.1 Definitions

• Personal Information: Various types of information recorded electronically or otherwise related to identified or identifiable natural persons, excluding anonymized information.
• Sensitive Personal Information: Personal information that, once leaked or illegally used, may easily lead to the infringement of the personal dignity of a natural person or harm to personal or property safety. This includes biometrics, religious beliefs, specific identity, medical health, financial accounts, tracking and location, and the personal information of minors under the age of fourteen. Please note that content that may be considered sensitive personal information will be marked in bold in this Policy, and all sensitive personal information will be managed in accordance with this Policy and applicable laws.

We hereby particularly remind you: (1) Our Services involve multiple functional scenarios, and the specific types and scope of personal information collected and used will vary depending on the functional scenarios different users choose to use. Please refer to the specific functional scenarios. (2) To realize the basic functions of our Services, you must authorize us to collect and use your necessary personal information. If you refuse to provide such information, you will be unable to use our Services normally. (3) To realize additional functions of our Services, you may choose to separately consent or not consent to our collection and use of the corresponding personal information. If you refuse to provide such information, you will be unable to use the relevant additional functions normally or achieve the intended functional effects, but it will not affect your use of our basic functions.

1.2 Specific Functional Scenarios

When you use our Services, we need/may need to collect and use your personal information or data. We appreciate you providing complete and accurate information and informing us when your information needs updating. If you do not provide us with complete and accurate information, or if you do not notify us that your information needs updating, you may not be able to use our Services normally. The specific functional scenarios we provide for you include:

1.2.1 User Registration and Account Management

When you choose to become a registered user, we will collect your mobile phone number and email address to establish, maintain, and manage your account, including sending you any updates to this Policy. We will verify the validity of your email address by sending an email verification code. If you refuse to provide the above information, you will not be able to become a registered user and can only use the browsing service.

After you become a registered member, you may choose to complete your user profile by voluntarily providing your name, birthday, gender, contact phone number, company name, position, company address, and postal code. The information in the profile enhancement is optional; not filling it out or incomplete filling will not affect your use of the services available to all registered users.

1.2.2 Order Placement and Management

When you order specific goods and/or services through this Application, we may collect the recipient's name, delivery address, recipient's phone number, invoice contact person, invoice address, and invoice contact phone number provided by you to generate the order. The order will also contain information about the goods and/or services you purchased, the specific order number, order creation time, and your remarks/information. We collect this information to help you complete transactions smoothly, ensure your transaction security, facilitate your order inquiries, provide customer service and after-sales service, and for other purposes.

If the recipient and/or invoice contact information you provide is not your own, you must ensure that you have obtained the consent of that recipient and/or invoice contact person, and that the information provided is true and accurate.

To facilitate your understanding and querying of order information and managing orders, we will collect order information generated during your use of our Services to display it to you and facilitate your order management.

1.2.3 Product Delivery

To ensure the smooth, safe, and accurate delivery of the goods you purchase when you subsequently transact with us, you may provide your recipient's name, delivery address, and recipient's phone number to the relevant logistics and distribution companies. We may also collect your recipient's name, delivery address, delivery port, and recipient's phone number to confirm your order delivery information with the relevant logistics and distribution companies for the purpose of delivering and fulfilling the order with you.

For the purpose of providing you with after-sales and dispute resolution services, we need to be informed of and confirm the delivery progress and status promptly. You agree that we may collect information related to the delivery progress of your order from the relevant logistics and distribution companies.

1.2.4 Customer Service and Dispute Handling

When you contact us or submit a request for during-sales, after-sales, or dispute resolution, we need you to provide necessary personal information to verify your identity in order to protect your account and system security.

To facilitate contacting you, helping you resolve issues promptly, or recording the resolution plan and results of related issues, we may collect, process, and store, within a reasonable period, records and related content of our communications/calls with you (e.g., account information, order information, other information you provide to prove relevant facts, and the contact details you leave). If you make inquiries, complaints, or provide suggestions regarding a specific order, we may process your account information and order information.

1.2.5 Data Analysis and Iteration/Upgrades

We may use users' personal information, information about their use of our Services and this Application, and questionnaire response information provided to us when participating in surveys (if applicable) for research, evaluation, and analysis to enhance and improve the quality of the services we provide to you, develop new services and applications, and upgrade and iterate this Application and related systems.

You understand and agree that based on adjustments to our business strategy, we may change the service content and functions of this Application, and may also interrupt, suspend, or terminate a certain service. If such changes involve your personal information, we will update this Policy and notify you in a timely manner.

1.3 Access to Your Device Permissions

To provide you with the services you have selected, you may need to grant us the corresponding access permissions on your device. Please note that you actively choosing to enable these permissions means you explicitly consent and authorize us to collect and use this personal information to achieve the above functions. Your closing of the permissions means you have canceled these authorizations, and we will cease to continue collecting and using this personal information of yours, and will also be unable to provide you with the functions corresponding to these authorizations. Your decision to close the permissions will not affect the processing of personal information previously carried out based on your authorization.

1.4 How We Use Cookies and Similar Technologies

Cookies and similar device information identification technologies are commonly used across the internet.

1.4.1 Cookies and Similar Technologies

When you use our Services, we may send one or more Cookies or anonymous identifiers (collectively, "Cookies") to your device to collect, identify, and store information about your access to and use of this Application. We promise not to use Cookies for any purposes other than those stated in this Policy. We use Cookies mainly to ensure the safe and efficient operation of relevant applications and services, enabling us to confirm the security status of your account and transactions (if applicable), troubleshoot crashes and delays-related anomalies, and help you save the steps and processes of repeatedly filling out forms and entering search content.

Simultaneously, we may use Cookies to show you information or features that may be of interest to you and optimize your choices regarding advertisements. Most browsers provide users with the function to clear browser cache data. You can perform corresponding data clearing operations or modify the acceptance level of Cookies or reject our Cookies. Due to these modifications, you may be unable to use services or corresponding functions that rely on Cookies. For details, please see AboutCookies.org.

1.4.2 Web Beacons and Pixel Tags

In addition to Cookies, we may also use other similar technologies such as web beacons and pixel tags on our website. For example, emails we send to you may contain click-through URLs linked to content on our website. If you click on that link, we will track this click to help us understand your preferences and improve customer service. A web beacon is typically a transparent image embedded in a website or email. With the help of pixel tags in emails, we can know whether the email has been opened. If you do not wish your activities to be tracked in this manner, you can unsubscribe from our mailing list at any time.

1.4.3 Authorizing Third Parties to Collect and Use Cookie Behavioral Data

We may embed third-party measurement and business intelligence analysis applications (hereinafter referred to as "Monitoring Programs"), such as the Second hand Analysis Systems, in the website. The Cookie files stored by you on this Application will be anonymized before being transmitted to the Monitoring Program and used solely for research, evaluation, and analysis purposes.

2. How We Provide Your Personal Information Externally

2.1 Entrusted Processing

We may entrust authorized partners to process your personal information and data so that they can provide certain services or perform functions on our behalf. We will only entrust them to process your information for the lawful, legitimate, necessary, specific, and explicit purposes stated in this Policy. Authorized partners can only access the information necessary to perform their duties, and we will require them through agreements not to use this information for any other purposes beyond the scope of the entrustment. If an authorized partner uses your information for purposes we have not entrusted, they will separately obtain your consent. Currently, the types of authorized partners we entrust include the following:

2.1.1 Service Providers

We use various service providers in our business operations. Our service providers are primarily located in China. We may appoint service providers to manage and/or operate certain functions or services on our behalf, and the proper execution of these functions or services may require the external provision of the personal information you have submitted. The services provided by these service providers include information technology services, online or mobile platform services, cloud storage services, marketing, promotion and advertising services, market research, and data analysis services.

To perform these tasks on our behalf, such service providers have limited access to your information where necessary and assume corresponding applicable data compliance and personal information protection obligations. We will also urge service providers to comply with all applicable laws, regulations, privacy policies/personal information protection policies, etc., to properly protect your personal information.

2.1.2 SDKs or Other Similar Applications from Authorized Partners

To enable you to use our services and functions, our application may embed SDKs or other similar applications from authorized partners. We will conduct strict security testing on the Application Program Interfaces (APIs) and Software Development Kits (SDKs) through which authorized partners obtain relevant information, and require authorized partners to comply with all applicable laws, regulations, privacy policies/personal information protection policies, etc., to properly protect your personal information.

2.2 Sharing

We will not share your personal information with companies, organizations, or individuals outside the scope described in this Policy, nor obtain your personal information from third parties, except in the following circumstances:

2.2.1 Sharing Required by Laws, Regulations, or Administrative/Judicial Authorities or Necessary for Fulfilling Statutory Obligations

We may share your personal information in accordance with legal and regulatory provisions, for the necessity of litigation or dispute resolution, or as required by administrative or judicial authorities according to law, as well as other necessities for fulfilling statutory obligations.

2.2.2 Sharing with Your Consent or Authorization

After obtaining your explicit consent, we will share your personal information with other parties or obtain your personal information from third parties.

2.2.3 Sharing Necessary for the Conclusion or Performance of a Contract to Which You Are a Party

If you purchase goods or services through us, we will, based on your choice, share the necessary information related to the transaction from your order information with the relevant providers of the goods or services to fulfill your transaction, delivery, and after-sales service needs.

2.2.4 Sharing Based on Compliance with Laws and Regulations for Social Public Interest or Public Health Emergencies

2.2.5 Sharing for the Protection of Major Legitimate Rights and Interests such as the Life or Property of the Personal Information Subject or Other Individuals but Where It Is Difficult to Obtain Their Authorized Consent

2.2.6 Sharing of Publicly Disclosed Personal Information

Personal information that you have voluntarily disclosed to the public or that we have collected from legally publicly disclosed information, such as through lawful news reports, government information disclosure, and other channels.

2.2.7 Sharing Within Affiliated Companies

For the purpose of this Policy, "Affiliates" refer to entities controlled by the EssilorLuxottica Group, where "control" means (a) directly or indirectly owning more than 50% (fifty percent) of the voting capital of any entity; (b) the power to directly or indirectly determine the management or policies of an entity.

For matters related to this Policy, you can contact our Affiliates through the contact methods described in Chapter 8 of this Policy.

To facilitate us and our Affiliates jointly providing certain services to you, recommending goods, services, and promotional information that may be of interest to you, and effectively managing your personal information, the mobile phone number and other personal information we collect may be shared with our Affiliates globally.

In all the above sharing situations, we will only share necessary personal information and are bound by the purposes stated in this Policy. If we share your sensitive personal information or if an Affiliate changes the purpose of use and processing of personal information, we will seek your authorized consent again. Please note that information you voluntarily share or even publicly post while using our Services may involve your or others' personal information or even sensitive personal information. Please be more cautious in your considerations and decisions.

2.3 Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:

2.3.1 Transfer with Explicit Consent Obtained

After obtaining your explicit consent, we will transfer your personal information to other parties.

2.3.2 In the Event of Merger, Division, Dissolution, Acquisition, or Bankruptcy Liquidation

If a transfer of personal information is involved, we will inform you of the name or contact details of the recipient and require them to continue to be bound by this Privacy Policy. Otherwise, we will require that company or organization to seek your authorized consent again.

2.4 Public Disclosure

We will publicly disclose your personal information only under the following circumstances:

2.4.1 Public Disclosure Based on Your Active Choice and Other Separate Consents

We may publicly disclose your personal information based on your active choice and other separate consents.

2.4.2 If You Seriously Violate Laws, Regulations, or Relevant Agreements/Rules

We may disclose your relevant violation behavior and the measures we have taken against you.

3. How We Protect Your Personal Information

We take appropriate measures to protect your personal information from unauthorized access, use, or disclosure. These measures include but are not limited to:

(1) We have a dedicated organizational body within our group responsible for privacy protection.

(2) We have implemented security protection measures consistent with industry standards to protect the personal information you provide, preventing data from unauthorized access, public disclosure, use, modification, damage, or loss. We take all reasonably practicable measures to protect your personal information. For example, data exchange between you and the "Services" is protected by SSL encryption; we use encryption technology to ensure data confidentiality.

(3) We implement corresponding restrictions on access to your personal information and monitor the access, use, and transfer of personal information.

(4) All our employees with access to your personal information must sign confidentiality agreements (or clauses) stipulating their obligation to comply with our personal information protection and confidentiality requirements.

(5) We require any business partners and third-party service providers with whom we share your personal information to comply with any applicable personal information protection and confidentiality requirements.

(6) We regularly provide personal information protection training to employees and third parties with access to personal information.

(7) In the unfortunate event of a personal information security incident, we will promptly inform you as required by laws and regulations and take possible remedial measures; simultaneously, we will actively report the handling of such incidents to the regulatory authorities as required.

(8) We will only retain your personal information for the period necessary to achieve the purposes stated in this Policy, unless there is a mandatory retention requirement by law. After your personal information exceeds the retention period, we will delete your personal information or anonymize it according to applicable legal requirements.

The internet is not an absolutely secure environment, and it is not possible to determine whether communication tools like email, instant messaging, and social software are fully encrypted. We recommend that you use complex passwords (if applicable) when using such tools and pay attention to protecting the security of your personal information, only providing personal information to others when necessary.

4. Your Rights

In accordance with relevant Chinese laws, regulations, and standards, as well as common practices in other countries and regions, we guarantee you the following rights over your personal information. Simultaneously, in appropriate circumstances, we will optimize functionalities to enable you to more conveniently access, correct, delete your personal information, and exercise the right to withdraw consent and cancel your account:

4.1 Accessing Your Personal Information

You have the right to access your personal information, except in circumstances provided by laws and regulations. You can exercise your data access right through the following means:

4.1.1 You can contact us through the methods under "How to Contact Us" in Article 8 of this Policy. We will respond to your access request within fifteen (15) working days after verifying your identity.

4.1.2 You can log in to this website, go to "My profile", and select "Edit" to access all or part of your personal information.

4.2 Correcting Your Personal Information

When you discover that the personal information we process about you is incorrect, you have the right to request us to make corrections. You can exercise your data correction right through the following means:

4.2.1 You can contact us through the methods under "How to Contact Us" in Article 8 of this Policy to submit a correction request. We will respond to your correction request within fifteen (15) working days after verifying your identity.

4.2.2 You can log in to this Application, go to "My profile", and select "Edit" to correct all or part of your personal information.

4.3 Deleting Your Personal Information

In the following circumstances, you can request us to delete your personal information by contacting us through the methods under "How to Contact Us" in Article 8 of this Policy:

(1) If our handling of personal information violates laws or regulations;

(2) If we have collected or used your personal information without obtaining your explicit consent;

(3) If our handling of personal information violates our agreement with you;

(4) If the purpose of processing has been achieved, cannot be achieved, or it is no longer necessary to achieve the purpose of processing;

(5) If we cease providing the application or corresponding services, or the retention period has expired.

If we decide to respond to your deletion request, we will also simultaneously notify, to the extent possible, entities that obtained your personal information from us and require them to delete it in a timely manner (unless otherwise stipulated by laws and regulations or these entities have independently obtained your authorization). After you or we assist in deleting the relevant information, due to applicable legal and security technology limitations, we may not be able to immediately delete the corresponding information from backup systems. We will securely store your personal information and restrict any further processing of it until the backup can be cleared or anonymized.

4.4 Changing the Scope of Your Authorized Consent

Our product display and order management service is a basic function of the application and requires your specific personal information to be provided. If you withdraw or change the scope of your consent, we may not be able to respond to your request to change the authorization scope, or after we respond, you will no longer be able to use our application. For other collected personal information and its use, you can give or withdraw your authorized consent at any time, which will not affect your use of the basic functions. You can withdraw your authorized consent by contacting us through the methods under "How to Contact Us" in Article 8 of this Policy. When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw consent will not affect the personal information processing previously carried out based on your authorization.

Please note that for certain types of personal information, such as information necessary for us to comply with obligations stipulated by laws and regulations, we may not be able to respond to your request to change the scope of authorization.

4.5 Canceling Your Account

You can apply to cancel the previously registered account by contacting us through the methods under "How to Contact Us" in Article 8 of this Policy.

After canceling the account, we will cease providing you with the corresponding application or services. If you request that we delete your personal information, we will delete or anonymize your personal information according to your request, except where otherwise provided by laws and regulations.

4.6 Objecting to Automated Decision-Making by Information Systems

In certain business functions, we may make decisions solely based on non-human automated decision-making mechanisms, including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you can contact us through the methods under "How to Contact Us" in Article 8 of this Policy.

4.7 Responding to Your Above Requests

For security purposes, you may need to provide a written request or otherwise prove your identity. We may first ask you to verify your identity before processing your request. We will provide a response within fifteen (15) working days. If you are not satisfied, you can also file a complaint by contacting us through the methods under "How to Contact Us" in Article 8 of this Policy.

For reasonable requests, we generally do not charge a fee, but for repeated or excessive requests, we may charge a certain cost fee as appropriate. We may refuse requests that are unreasonably repetitive, require excessive technical means (e.g., developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are highly impractical (e.g., involving information stored on backup tapes).

In the following circumstances, we will be unable to respond to your request:

(1) Related to the performance of obligations by the personal information handler as required by laws and regulations;

(2) Directly related to national security or national defense security;

(3) Directly related to public safety, public health, or major public interests;

(4) Directly related to criminal investigations, prosecutions, trials, and execution of judgments;

(5) Where the personal information controller has sufficient evidence indicating your subjective malice or abuse of rights;

(6) For the protection of major legitimate rights and interests such as the life or property of the personal information subject or other individuals, but it is difficult to obtain their consent;

(7) Where responding to the request of the personal information subject would cause serious harm to the legitimate rights and interests of the personal information subject or other individuals or organizations;

(8) Involving trade secrets.

5. How We Handle Children's Personal Information

This Application is intended for adults. Children should not create their own personal information subject accounts without the consent of their parents (or guardians, hereinafter the same). For cases where children's personal information is collected with parental consent, we will only process the children's personal information where permitted by law, with parental explicit consent, or when necessary to protect the child.

Although local laws and customs have different definitions of children, we consider anyone under the age of 18 as a child. If we discover that we have collected a child's personal information without first obtaining verifiable parental consent, we will try to delete the relevant data as soon as possible. We reserve the right to request users to provide age information.

6. How Your Personal Information is Stored and Transferred Globally

Personal information collected and generated by us within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. Currently, we do not transfer the above information overseas. If in the future we need to transfer it overseas, we will seek your separate consent, comply with relevant national regulations, and ensure your personal information receives protection in the recipient country that is substantially equivalent to that within China.

7. How This Policy is Updated

This Policy may be subject to change. Without your explicit consent, we will not diminish the rights you are entitled to under this Policy. We will post any changes made to this Policy on this page. For major changes, we will also provide more prominent notice (including, for certain services, notifying you via phone calls, emails, push notifications, etc.).

Major changes referred to in this Policy include but are not limited to:

(1) Significant changes in our service model. Such as changes in the purpose, method, types, or retention period of personal information processing;

(2) Changes in our name;

(3) Changes in the main entities with whom personal information is shared, transferred, or publicly disclosed;

(4) Significant changes in your rights regarding personal information processing and the procedures for exercising them;

(5) Changes in the department responsible for personal information security, our contact methods, and complaint channels;

(6) When a personal information security impact assessment report indicates high risk.

8. How to Contact Us

If you have any questions, comments, or suggestions regarding this Policy, please send an email to webmaster@essilorchina.com. Under normal circumstances, we will respond within fifteen (15) working days.

If you are dissatisfied with our response, particularly if our personal information handling practices have harmed your legitimate rights and interests, you may also file a lawsuit with the court of competent jurisdiction in our domicile. Please note that we may not respond to inquiries unrelated to this Policy or your personal information rights.