iStylist App Privacy Policy

Privacy Policy

Effective Date 7 Febuary 2019

Torga Optical Proprietary Limited (“Torga,” “we,” “us” or “our”) operates a mobile application and related website (the “Online Glasses Purchase App”) for the purpose of performing a virtual glasses fitting and online purchases. This Privacy Policy also applies to your use of the Online Glasses Purchase App.

By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes.

This Policy is governed by the Electronic Communications and Transactions Act 25, 2002 (“ECTA”) and the Protection of Personal Information Act 4, 2013 (“POPI”) which you are encouraged to read for further information on the principles applicable herein.  In certain circumstances, Torga will be obliged to collect and use information in accordance with the Health Professions Act 56, 1974 and Regulations.  In all cases, where there is any inconsistency or conflict between this Privacy Policy and the applicable legislation and regulations, the latter will take precedence.

Please note that this Privacy Policy does not apply to third party websites (“Third Party Services”), such as Facebook, Twitter, Pinterest, Instagram, Snapchat, and Google+, that we do not own or control, even if you access them through our Services. We try to work only with Third Party Services that share our respect for your privacy, but we cannot take responsibility for their practices, content, or privacy policies. We encourage you to carefully review the privacy policies of any Third Party Services you access so that you know how they will collect, use, and share your information.

If you have any questions, please reach out to us at [email protected]

1. What Information does Torga Collect

Information you provide us:

•            When you create an account. When you create an account with us, you provide a name, email address, and password.
•            When you use our Services. If you make a purchase, we request information from you to facilitate the transaction and provide you with the purchased product. You may also provide us with information when you use certain online features, such as the Online Glasses Purchase App. This information may include (i) your name, email address, phone number, and date of birth, (ii) prescription information, including any images of prescriptions you may provide to us and any information you give us through the pupillary distance measurement function of our Services, (iii) information about the products you try on and purchase, and (iv) information about other people that use the Online Glasses Purchase App from your mobile device. If you provide us with an image of your prescription, we obtain any information that appears on the prescription form.
•            When you use the Online Glasses Purchase App. When you use the Online Glasses Purchase App, you disclose certain information about yourself by (1) answering a series of questions (“Eligibility Questionnaire”) to determine whether you are eligible to use the Online Glasses Purchase App, and (2) performing a series of measurements to match relevant glasses to your face (the “Services”).
  "Facial Features" is information that relates to your facial characteristics (including shape, size, color, hair) that is derived from your use of the Online Glasses Purchase App. The disclosure, collection and use of some Facial Features may be subject to laws and regulations. You represent that any Facial Features that you disclose to us are your Facial Features that you are authorized to disclose them to us. “Personal Information” is information about you, including your first name, last name, age, gender and demographic information, derived from your use of the Online Glasses Purchase App. Your Torga account contains Personal Information and/or Facial Features Information, and we will access such information when you use the Online Glasses Purchase App. In addition, subject to applicable law, we may use an automated decision-making or profiling engine in order to predict additional, non-identifiable information about you, such as your age, gender, and other aspects of your personality (“Predictions”), based on your data that we collect directly from you.
•            When you contact us. We do everything possible to make sure you have an exceptional shopping experience. If you contact us in person, by phone (calling or texting), email, instant message (including Facebook Messenger), live chat, through social media or our Online Glasses Purchase App, or by some other means, we may keep a record of your contact information and the content of the communication for later reference. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services. We receive responses to any survey that you choose to complete for us.

Information we collect from third parties:

•            Information from third party services. Some parts of our Services can be linked to other accounts you have with Third Party Services (“Third Party Accounts”) or you may be able to register for an account on our Services with your Third Party Account. If you connect a Third Party Account to our Services or interact with us through a Third Party Account, we may receive information about you, including your Third Party Account profile information, your photograph, and your use of the Third Party Account (for example, if you select a Torga product to purchase through the account). If you mention us through your Third Party Account, we may collect publicly available information and content related to your comment. If you wish to limit the information available to us, you should visit the privacy settings of your Third Party Accounts to learn about your options.
•            Information from other third parties. We may collect information about you from other third parties, including demographic information, and combine this information with other information we collect about you.

Information we automatically collect:

•            Web logs and usage information. We record certain information and store it in log files when you interact with our Services. This information may include device and browser information, internet protocol (IP) address, URLs of referring/exit pages, and search terms.
•            Mobile device information.

◦       In-store Wi-Fi. When you connect to our in-store Wi-Fi, we receive information about you and your device, including your device’s MAC address, IP address, received signal strength indicator (RSSI), and technical details about your device such as its operating system, device type (including make and model), and technical capabilities. We will also receive information about how you use our Wi-Fi network while you are connected, including the store location, the areas of the store you visit, the names and/or Internet addresses of the websites you visit and the applications you use, and how long you interact with such sites or applications. If your mobile device is configured to search for available Wi-Fi networks, we may receive information about your device even if you choose not to connect to our Wi-Fi services.

◦       Downloading Our Online Glasses Purchase App. When you download and use our Online Glasses Purchase App, we receive information from your mobile device, such as IP address, device information, and unique device identifiers. We may also receive information about your precise location from your device, but only if you enable location tracking on your device. We may collect location data when your device is near our in-store systems, even if you are not currently using the app. You may turn off this location tracking at any time in your app settings or by disabling it on your device.

•            Information from cookies and other technologies. Like most websites, our Services may incorporate technology such as “pixel tags”, “web beacons”, and “cookies” that allow us and our service providers to collect information about your actions on our Services. Our service providers may collect information about your online activities over time and across different online services. Cookies  are small files that web servers may place on your computer when you visit a website. You may be able to set your web browser to reject cookies entirely or require that it request permission from you before accepting each new cookie. You can also delete cookies from your web browser once you leave a website.
  
•            Information from in-store technologies. We may also collect information when you are visiting our stores. Like most retailers, we have in-store video cameras that, in addition to serving a security function, help us understand customer behavior within our physical spaces. Our service providers may also collect information about your mobile device from other tracking technologies while you are near or in our stores to help us better understand our customers and how they use our Services.

2. How We Use Your Information

1.  We primarily use your information to provide and enhance our Services and your experience with Torga. Some ways we may use your information include:

•            to provide, personalize, and improve our products and our Services
•            to facilitate your shopping experience and to offer you glasses with high accuracy fitting you, based on your face and the frame characteristics
•            to communicate with you, including to respond to your comments or questions, and to send you updates about your order
•            to understand your use of our Services to help us improve the customer experience
•            to provide you information, recommendations, and marketing materials about our business partners, products and Services
•            to deliver gift cards in accordance with your instructions
•            for our other internal business purposes

1.  We may use location information collected from your mobile device to enhance your shopping experience and to provide you with location-based services, such as advertising, search results, and other personalized content, as well as to assist us with foot traffic measurement and service improvements in-stores.

Photos, Scans, and Images. When you submit (or grant us permission to take) a photo, facial scan, or other image of you, we don’t share those photos, scans, or images, or any facial data captured in the facial scans, with any third parties, but we may use them as described below:

•            to measure your pupillary distance and segment height, and to gather other optical information
•            to map and measure your facial features
•            to address certain problems or concerns you may have with your glasses
•            to help us better understand how our frames fit our customers
•            subject to applicable privacy laws we may use Predictions to improve the Service’s predictive capabilities and help us suggest frames for our customers.

We don’t store any facial scans submitted through the iPhone X TrueDepth camera.

3. How We Share Your Information

If we share your information, we do so only as described below.

With vendors

We may provide your information to our contractors, agents, and service providers as necessary to enable them to perform certain services for us, including but not limited to:

•            order fulfilment
•            delivery services
•            account registration
•            website-related services, such as web hosting
•            improvement of website-related services and features
•            maintenance services
•            data analytics

With marketing and advertising partners

Subject to applicable law, we may share your information with third parties for their advertising and marketing purposes, which may include sending you direct mail that may interest you. If you prefer that we not share your address with third parties, you can opt out at [email protected] .

You can learn about how to opt out of receiving personalized website advertisements from our advertising partners by visiting the opt-out sections on the websites of each of those organizations. Note that if your election to opt out is managed through cookies, if you delete these cookies or use a different browser, you will have to make the same selection again.

One of the third party services that we use to track your activity on our Services is Google Analytics. If you do not want Google Analytics to collect and use information about your use of our Services, then you can install an opt-out tool in your web browser (https://tools.google.com/dlpage/gaoptout). You also may opt-out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings located at https://www.google.com/settings/ads. If available in your jurisdiction, you can also visit your device’s settings or install the AppChoices app to learn more about how you may opt out of receiving personalized ads in mobile apps.

On an aggregated or de-identified basis

Subject to applicable privacy laws, we may share aggregated or de-identified information (which cannot reasonably be used to identify you) with service providers or other third parties. These service providers and third parties may also share with us aggregated or de-identified information that they have independently developed or acquired.

In connection with business transfers

If the ownership of all or substantially all of our business changes, or we otherwise transfer assets relating to our business or any of the Services to a third party (such as by merger, acquisition, bankruptcy proceeding, or other change of control transaction), we may transfer or sell your information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to this Privacy Policy unless we notify you otherwise.

To protect us and others

We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with any applicable law, court order, subpoena, legal process, or enforceable governmental request; cooperate with law enforcement; enforce or apply this Privacy Policy, our Terms of Use, and other agreements; detect, prevent, or otherwise address fraud, security or technical issues; or protect the rights, property, or safety of Torga, our employees, our users, or others.

With your consent

Except as we’ve stated above, we will notify you before we share your identifiable information with any third parties.

4. Access to Your Information and Choices You Have With Your Torga Account

Through your account settings, you can access, view, and edit the following information you’ve provided to us:

•            name
•            password
•            mailing address
•            email address
•            phone number

You can delete any of the above information, and contact us with questions or concerns about your information, by emailing [email protected]. The information you can view, edit, and delete may change as our Services change.

If you decide you don’t want to receive email from us, you can select the “opt out” provision in our communications to unsubscribe, you can email us at [email protected], or you can contact customer support. Unsubscribing will stop you from receiving most types of email communications, but it may not prevent you from receiving emails about orders or transactions you place through our Services or to emails in response to a specific request from you, such as password recovery. If you wish to stop receiving notifications from us on your mobile device, you can update your device settings.

6. We are Committed to Protecting Your Information

We take the protection of your information very seriously. We understand the sensitivity of the information you may give us. Therefore, we take many security measures (physical, electronic, and procedural) to help keep your information safe. For example, we limit access to authorized employees and third parties who are under an obligation to keep all such information confidential. Also, we allow parties to access your identifiable information for permitted business purposes only. Unfortunately, even though we use commercially reasonable efforts to protect your information, we cannot guarantee complete security. Any information that you provide to us is done so entirely at your own risk.

7. Children’s Information

We are especially sensitive about children’s information. We do not knowingly allow individuals under the age of 18 to use the Online Glasses Purchase App and we do not knowingly collect personal information from individuals under the age of 18. If you are a parent or legal guardian of a minor child, you may use our Services on behalf of such minor child, subject to applicable law. If you have questions concerning our information practices with respect to children, or if you believe an individual under the age of 18 has provided us with personal information, please email us at [email protected].

9. Changes to this Privacy Policy

We occasionally review this Privacy Policy to make sure it complies with applicable laws and conforms to changes in our business. We may need to update this Privacy Policy, and we reserve the right to do so at any time. If we do revise this Privacy Policy, we will update the “Effective Date” at the top of this page so that you can tell if it has changed since your last visit. Your continued use of our Services constitutes your acceptance of the terms of the Privacy Policy as amended or revised by us from time to time.

10. Contact Us

If you have any questions about viewing or updating your information, this Privacy Policy, or our privacy practices, please contact us at [email protected].