When accessing https://www.specic.com (the “Site”), we may collect certain information about you during your visit in connection with our smart glasses online configuration services. We adhere to the principle of "data minimization" and only collect the minimum amount of personal information necessary to provide and improve our services, and we will never use our Site to collect personal information as the primary purpose.

Similar to other commercial websites, our Site utilizes a standard technology called “cookies” (see explanation below) and server logs to collect information about how our Site is used. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed (including smart glass models, configuration tools, and product details), time spent at our Site, the websites visited just before and just after our own, and your IP address.

1. Use of Cookies

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. We comply with the EU ePrivacy Directive (Cookie Directive), clearly classifying cookies and providing you with control rights.

On SpeCiC, cookies may be used to:

• Remember your configuration preferences (e.g., selected frame style, lens type, color, or AI feature settings) for a seamless user experience.
• Track your interaction with the online configuration tool to improve its functionality.
• Personalize product recommendations based on your browsing history (e.g., preferred smart glass models or features).

You can adjust your browser settings to refuse non-essential cookies or alert you when cookies are being sent. You can also manage your cookie preferences through the cookie consent banner on our Site. However, disabling non-essential cookies may limit your ability to use certain features of our Site, such as saving your configuration progress. Please note that necessary cookies (essential for core services like checkout and login) cannot be disabled, as they are required to provide you with our core services.

2. IP Addresses

IP addresses are used by your computer every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web server as part of demographic and profile data known as “traffic data” so that data (such as the web pages you request or configuration results) can be sent to you. We may use IP addresses to analyze usage patterns, diagnose technical issues, and ensure the security of our Site. We will not use IP addresses or other non-identifiable data to identify you personally without your explicit consent.

3. Personal Information Collection

In addition to the information collected via cookies and server logs, we may collect personal information that you voluntarily provide to us, including but not limited to: We will never collect personal information that is irrelevant to our smart glasses online configuration services and product sales, and we will not use free gifts or incentives to induce you to provide personal information, except when such incentives are part of a purchase or marketing activity and the primary purpose is not to collect personal information.

• Account Information: If you register an account, we may collect your name, email address, password (encrypted storage), phone number, and shipping address. This information is used to manage your account, process orders, and provide after-sales services. We will never sell, rent, or lease your account information to any third party without your explicit consent.
• Configuration-Related Information: Photos or images you upload to use our virtual try-on tool (to visualize how smart glasses fit your face) and your configuration selections (e.g., frame size, lens material, AI camera settings, connectivity preferences). For users purchasing prescription eyewear, we also collect your prescription parameters (including sphere, cylinder, axis, prism, add power, and other relevant data), which are used solely for lens production and prescription verification. The facial photos you upload for virtual try-on and your prescription lens parameters are classified as sensitive personal information under GDPR and other regional regulations. We implement enhanced protection measures for this information: it is encrypted during transmission and storage, and we will never use such sensitive information for advertising purposes without your explicit consent.
• Order Information: If you purchase a configured smart glass product, we may collect payment details (processed via third-party payment processors), billing address, and delivery instructions. We do not store credit card details on our servers; all payment transactions are processed through secure, third-party payment processors (e.g., Stripe, PayPal) that comply with industry standards (e.g., PCI DSS), to ensure the security of your payment information and avoid unauthorized access.
• Communication Information: If you contact us via email, phone, or contact forms, we may collect the content of your communications, your contact details, and our responses. This information is used solely to resolve your inquiries, handle complaints, and improve our services.

4. How Do We Use the Information That You Provide to Us?

Broadly speaking, we use personal information for the following purposes. We only use your personal information for the purposes we disclose to you at the time of collection, and will not use it for any other purposes without your explicit consent:

• To provide and improve our smart glasses online configuration services (e.g., processing your virtual try-on requests, generating customized product previews, and fulfilling your orders).
• To deliver customer service and support (e.g., responding to your inquiries, troubleshooting configuration issues, and updating you on order status).
• To personalize your experience (e.g., recommending smart glass models or features based on your configuration history and preferences).
• To communicate with you about our products, services, and promotions (with your explicit consent, where required by law). We will never send you promotional communications without your opt-in consent.
• To administer our business activities, including analyzing usage data to optimize the Site’s performance and developing new features or services. Such data analysis will be conducted using anonymized or aggregated data that cannot identify you personally.
• To protect the security and integrity of our Site, prevent fraud, and comply with legal obligations.

SpeCiC will not obtain personally-identifying information about you when you visit our Site unless you choose to provide such information to us. We will not sell, rent, or otherwise transfer your personal information to unaffiliated third parties without your explicit consent at the time of collection, except as required by law. We will never sell your contact information under any circumstances.

5. Disclosure of Your Personal Information

We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights, property, or the safety of our users or others. We will only disclose the minimum amount of personal information necessary to meet the legal requirement, and will notify you of such disclosure if permitted by law.

6. Email Policies

We are committed to keeping your email address confidential. We do not sell, rent, or lease our subscription lists to third parties, and we will not provide your personal information to any third party individual, government agency, or company at any time unless strictly compelled to do so by law.

We will use your email address solely to:

• Confirm your account registration and configuration requests.
• Update you on order status, shipping details, and delivery confirmations.
• Provide customer service responses and technical support.
• Send you product updates, new feature announcements, or promotional offers (if you have opted in to receive such communications).

We will maintain the information you send via email in accordance with applicable federal and local laws, and will delete or anonymize such information once the purpose of collection is fulfilled.

7. CAN-SPAM Compliance

In compliance with the CAN-SPAM Act, all emails sent from our organization will clearly state who the email is from and provide clear information on how to contact the sender. In addition, all email messages will contain concise information on how to unsubscribe from our mailing list so that you receive no further email communication from us. Unsubscribe requests will be processed promptly, within the time limit required by law.

8. Choice/Opt-Out

Our Site provides users the opportunity to opt out of receiving promotional communications from us by:

• Following the unsubscribe instructions located at the bottom of any email you receive from us.
• Adjusting your communication preferences in your SpeCiC account settings.

Opting out of promotional communications will not affect essential service-related emails (e.g., order confirmations, configuration updates, or customer support responses). We will not send you promotional communications after you have opted out, and will update your preference promptly.

9. Use of External Links

https://www.specic.com may contain links to third-party websites (e.g., payment processors, shipping providers, or partner brands). SpeCiC cannot guarantee the accuracy, security, or privacy practices of any linked site. Links to or from external sites not owned or controlled by SpeCiC do not constitute an endorsement by SpeCiC or any of its employees of the sponsors of these sites or the products, services, or information presented therein. We encourage you to review the privacy policies of any third-party sites you visit, as their privacy practices may differ from ours.

10. How Do We Protect Your Information and Secure Information Transmissions?

We take reasonable and industry-standard security measures to protect your personal information from unauthorized access, disclosure, modification, or destruction:

• Email is not recognized as a secure medium of communication. For this reason, we request that you do not send sensitive personal information (e.g., payment details, passwords) to us by email. However, if you choose to do so, you do so at your own risk.
• Sensitive information (e.g., payment details, account credentials, and uploaded photos) transmitted through our Site is protected via Secure Sockets Layer (SSL) encryption.
• We use industry-standard security measures (e.g., firewalls, access controls, and data encryption) to protect your personal information from unauthorized access, disclosure, or modification.
• We may use software programs to create summary statistics (e.g., number of users who configured a specific smart glass model) for the purpose of assessing Site performance, identifying user preferences, and improving our services. Such statistics will not contain any personally identifiable information.
• For Site security purposes, we monitor network traffic to identify unauthorized attempts to upload or change information, cause damage, or access restricted areas.
• We regularly review and update our security measures to adapt to changes in technology and regulatory requirements, ensuring the continuous protection of your personal information.

11. Data Retention

We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. Once the retention period expires, we will permanently delete or anonymize your personal information in a secure manner to ensure it cannot be recovered or identified. Specifically: account information will be retained for as long as your account is active; order and configuration information will be retained until the expiration of the statutory after-sales period and applicable legal retention requirements; communication information will be retained until your inquiry or complaint is fully resolved and the statutory retention period expires.

12. Cross-Border Data Transfer

As a China-based seller, your personal information will be collected and stored on secure servers located in mainland China. We fully comply with cross-border data transfer regulations of the EU, UK, US, and China, ensuring that any cross-border transfer of your personal data is conducted lawfully, fairly, and with adequate safeguards to maintain the same level of data protection outlined in this policy.

For users in the European Union (EU) and United Kingdom (UK): All cross-border transfers of your personal data from the EU/UK to mainland China are protected by the European Commission-approved Standard Contractual Clauses (SCCs), which are legally binding agreements that guarantee your personal data receives an adequate level of protection consistent with GDPR and UK DPA 2018 requirements. You may request a copy of the executed SCCs at any time by contacting our customer support team via the channels listed in the "Contact Us" section of this policy.

For users in the United States (including California): All cross-border data transfers comply with the CCPA and other applicable U.S. federal and state privacy laws. We only transfer your personal information across borders to the extent necessary to fulfill your order, provide our services, or comply with legal obligations, and we will never transfer your personal information in a way that reduces your privacy rights under applicable U.S. law.

We implement strict safeguards for all cross-border data transfers, including:

• End-to-end encryption for all personal data transmitted across borders;
• Only sharing personal data with third-party service providers that have demonstrated sufficient data protection capabilities, and requiring all partners to sign binding data processing agreements that mandate compliance with applicable privacy laws;
• Regular audits and reviews of our cross-border data transfer practices to ensure ongoing compliance with global privacy regulations.

You have the right to obtain detailed information about our cross-border data transfer practices, including the legal safeguards we use, by contacting our data protection team via the contact channels provided in this policy.

13. Your Data Rights

In accordance with applicable data protection laws (including GDPR, CCPA, and UK DPA 2018), you have the following rights regarding your personal information. We will respond to all valid, verifiable requests within 5 business days, and will not discriminate against you for exercising any of these rights, in compliance with applicable regional privacy laws.

• Right of Access: You have the right to request confirmation of whether we process your personal information, and to request a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request that we correct any inaccurate, incomplete, or outdated personal information we hold about you.
• Right to Erasure (Right to be Forgotten): You have the right to request that we delete your personal information in circumstances where: the information is no longer necessary for the purpose it was collected; you withdraw your consent; you object to our processing; or the processing violates applicable laws.
• Right to Withdraw Consent: Where we rely on your consent to process your personal information (e.g., for promotional communications), you have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
• Right to Data Portability: You have the right to receive the personal information you provided to us in a structured, machine-readable format, and to request that we transfer this data to another data controller where technically feasible.
• Right to Object: You have the right to object to our processing of your personal information for direct marketing purposes, or for processing based on our legitimate interests.
• Right to Opt Out of Sale of Personal Information: In compliance with CCPA, we confirm that we do not sell your personal information. We provide a clear "Do Not Sell My Personal Information" link on our Site homepage for California users to confirm their rights.

To exercise any of the above rights, you may contact us via email at service@specic.com, our Site live chat, or the phone number listed in the "Contact Us" section. We may request reasonable identity verification to ensure the security of your personal data before processing your request.

14. Children's Privacy

Our Site and services are not intended for, and we do not knowingly collect personal information from, children under the age of 16 in the European Union, or under the age of 13 in the United States (in compliance with the Children's Online Privacy Protection Act, COPPA).

If we become aware that we have inadvertently collected personal information from a child within the above age ranges, we will immediately take steps to permanently delete the information and terminate any associated account. If you believe we have collected information from a child, please contact us immediately via the channels listed in this policy.

15. Policy Updates

We reserve the right to amend this privacy policy at any time to align with operational updates, service changes, or new legal and regulatory requirements.

All material changes to this policy will be posted on this page with a revised effective date, and we will notify you via email or a prominent notice on our Site at least 30 days before the changes take effect. Policy updates apply only to personal information collected after the revised effective date; personal information collected before the update will continue to be governed by the version of the policy in effect at the time of collection.

We will never use your personal information in a manner materially inconsistent with this policy without your explicit prior consent.