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Privacy Policy
June 2026
Introduction
This Privacy Policy (“Policy”) explains how Shamir Optical Industry Ltd. and its corporate group affiliates (“Shamir”, the “Company,” “we”, “us”, “our”) collect, use, hold and secure your personal information when you participate in Shamir’s Partnership Club™ Program (the “Program”). It also sets out your rights in relation to your personal information, including how to make a complaint and how we deal with complaints.
In this Policy, “personal information” or “personal data” means any information or opinion about an identified individual or an individual who is reasonably identifiable, whether true or not. It does not include information that is de-identified.
Shamir is an international company headquartered in Kibbutz Shamir, Israel, that develops and manufactures optical lenses for eyeglasses, contact lenses, and other optical wear.
Our Program is not directed at individuals under the age of 18. We do not knowingly collect information from children under the age of 18.
This Policy may be amended from time to time. Where the change is material, we will take reasonable steps to notify you in advance, including by contacting you directly where we hold your contact information on file and by publishing the updated Policy before its effective date.
Contact us
If you have any questions, comments, or concerns regarding this Policy or our handling of your personal information, please contact us at Legal@Shamir.co.il.
What personal information we collect and for what purpose
The types of personal information we collect about you depends on the dealings you have with us, and may include the following:
| Scenario | Purposes | Categories of personal information processed |
|---|---|---|
| You enroll in Shamir’s Partnership Club™ Program | Giving you access to the Partnership Club™ Program, managing your account and profile. Tracking and redeeming points or rewards, providing member-exclusive offers, and (with your consent) sending promotional emails, SMS, and direct mail. Sending transactional communications (order confirmations, receipts, shipping updates), sending service-related notices and updates. | Your name (as an individual), your shop’s name, country of origin, email address, telephone number. Your professional or educational credentials. |
| You do business with Shamir | Billing, invoicing, and collections. Shipping and delivery. Returns, refunds, and exchanges. Offering you the benefits of the Partnership Club™ Program in accordance with your business metrics. Communicating product recalls or safety notices. Conducting surveys and collecting feedback. Developing new products, features, or services, and improving existing products and services. | Shamir products you obtained or purchased (purchasing history), Shamir products you considered, and purchasing tendencies. |
| You access and use Shamir Personal | Giving you access to Shamir Personal and its features and functions, including support and service inquiries, and responding to inquiries and requests. Training and improving algorithms and AI/ML models, user experience research and usability testing, bug detection and troubleshooting, analyzing usage patterns and trends, personalizing content and user experience, product recommendations, customer segmentation and statistical analysis. Displaying targeted/personalized advertising, retargeting and remarketing campaigns. | Free-text you submitted in interactive features, files/media you uploaded (including their metadata), in-product chat/communications transcripts, behavioral profiles & inferences, precise geolocation events, session recordings/screen replays, search queries inside the platform, feature usage events & clickstream, authentication & security telemetry, error/crash logs, device/browser identifiers & cookies/SDK IDs, IP address & coarse location |
You do not have a legal obligation to provide the information that we request. It is at your discretion. However, if you choose not to provide this information to us, you may not be able to participate in the Program.
Methods and sources for collecting your personal information
We collect personal information from several sources:
- Directly from you – we collect personal information that you voluntarily provide to us when you participate in Shamir’s Partnership Club™ Program (including personal information received by us when you sign up using SSO through the Shamir Personal platform).
- Through the devices you use to access the Program – when you access the Program, we automatically collect personal information from your device. This information may be collected through cookies, software development kits, and similar tracking technologies embedded in the Program.
Sharing your personal information
We will not share your information with third parties, except as set out below or where you provide us with your consent to do so.
| Scenario | Purposes | Third parties involved |
|---|---|---|
| We will share your information with our service providers who assist us with the internal operations of the Company’s business. These providers are authorized to use your personal information in this context only as necessary to provide these services to us and not for their own promotional or other purposes. | Operating the Company’s business and the Program | Third party providers, including (amongst others) operators of cloud hosting services to store your data, cybersecurity systems to secure our computing systems and databases, email distribution services, customer support management systems, marketing services and other services. |
| We will share your personal information with our affiliates and subsidiaries | Operating the Company’s business and the Program | Shamir affiliates and subsidiaries. |
| If you violate any applicable law while doing business with us | Responding to, handling, and mitigating suspected violations of law that could impact the Company. | Competent authorities, legal counsels, and advisors. |
| If we are required to disclose your information to a judicial, governmental, or regulatory authority | Complying with legal, judicial and ethical requirements from a competent authority. | Competent authorities. |
| If the Company’s operations are organized within a different framework, or through another legal structure or entity | Enabling a structural change in the Company. | The target entity of the merger or acquisition, legal counsels, and advisors. |
Data retention and security
We retain your information as long as you are an active member of the Partnership Club™ Program
We will retain your information as long as you are an active member of the Partnership Club™ Program. Thereafter, we will still retain your personal information as necessary for a wind-down period, and to comply with our legal obligations, resolve disputes, establish and defend legal claims, and enforce our agreements.
If we no longer need to hold your personal data for any reason or we are no longer required by law to keep it, we will take reasonable steps to de-identify or destroy that information. These steps may vary depending on the nature of the data, the way it was collected, and how it was stored.
We implement measures to secure your information
We take reasonable steps to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include technical, administrative and physical safeguards appropriate to the sensitivity of the information. However, no system is entirely secure, and we cannot guarantee that your personal information will be immune from all security risks.
Additional Information for Individuals in Israel
When you enroll in the Program, you also provide your consent to this Policy. Your consent to this Policy is at your discretion and choice. However, if you do not consent to this Policy, you will not be able to enroll in the Program.
You have a right to obtain access to the information the Company has about you. If you review the information the Company has about you and find it to be incorrect, incomplete, unclear, or outdated, you may ask that the Company correct or delete it.
By consenting to this Policy, you also consent to the Company transferring your personal information across international borders to recipients described in the chapter above titled “Sharing your personal information.” These recipients are at times located in countries outside Israel.
Additional Information for Individuals in the EEA or UK
Controller and EU representative
The data controller of the personal data we collect and process when you participate in the Program is:
Shamir Optical Industry Ltd. is an Israeli company with a business address at Kibbutz Shamir, Upper Galilee, 1213500, Israel. Tel. +972-4-6947777. Email: Legal@Shamir.co.il
Shamir RX Italia S.r.l is the representative of the non-EU Shamir entities in the EU, to represent it with regard to its respective obligations under the GDPR, in accordance with Article 27 of the GDPR.
Shamir RX Italia S.r.l contact details: Via Castelmorrone 72, 35138 Padova, Italia. Email address: shamirrxitaliasrl@pec.it
International data transfers
To facilitate the processing of your information, we transfer your information to countries outside the EEA and the UK, including Israel, Canada, Australia and the United States. Transfers to countries outside the EEA and the UK are subject to lawful mechanisms designed to protect your personal data; Transfers to Israel are subject to the European Commission’s and the ICO’s recognition of Israel to be providing an adequate protection to EU/UK personal data.
For transfers to countries that are not considered by the European Commission and the ICO to provide an adequate level of protection to EU/UK personal data, Shamir has entered into standard contractual clauses approved by the European Commission and the ICO.
In case you require additional information concerning the transfer and/or safeguards of your personal data, we invite you to contact us at: legal@shamir.co.il.
Legal basis for processing your personal data
| Purpose or Scenario | Legal Basis |
|---|---|
| Giving you access to the Partnership Club™ Program, managing your account and profile, and offering you the benefits of the Partnership Club™ Program in accordance with your business metrics. | Performance of a contract. |
| Providing member-exclusive offers, sending promotional emails, SMS, or direct mail. | Consent. |
| Billing, invoicing, and collections. Shipping and delivery returns, refunds, and exchanges. Sending transactional communications (order confirmations, receipts, shipping updates), and sending service-related notices and updates. | Performance of a contract. |
| Communicating product recalls or safety notices. | Our compliance with legal obligations regarding product safety. |
| Conducting surveys and collecting feedback. | Our legitimate business interest in learning about partners’ views, assessments, and feedback. |
| Developing new products, features, or services, and improving existing products and services. | Our legitimate business interest in developing new and enhanced products. |
| Giving you access to the Program and its features and functions, including support and service inquiries, and responding to inquiries and requests. | Our legitimate business interests in providing you access to the features and functions of Shamir Personal, and in responding to your inquiries and support and service requests. |
| Training and improving algorithms and AI/ML models, user experience research and usability testing, bug detection and troubleshooting, analyzing usage patterns and trends, personalizing content and user experience, product recommendations, customer segmentation and statistical analysis. | Our legitimate business interest in enhancing our business, products, and services. |
| Displaying targeted/personalized advertising, retargeting, and remarketing campaigns. | Consent. |
| Responding to, handling, and mitigating suspected violations of law impacting the Company. | Legitimate interests in defending and enforcing violations and breaches that are harmful to the Company, or, our compliance with legal obligations (where the authority is competent under EU/UK law). |
| Complying with a binding request from a competent authority. | Our legitimate interests in complying with mandatory legal requirements imposed on us, or, our compliance with a legal obligation where the authority is competent under EU/UK law. |
| Enabling a structural change in the operation of our Company’s business. | Legitimate interests in our business continuity. |
Data subject rights
If you are in the EU or the UK, you have the following rights under the GDPR. To exercise them, please contact us at Legal@Shamir.co.il.
- Right to Access and receive a copy of your personal information that we process. Your right to access data about you will be restricted if this is required to protect the rights and freedoms of others—for example, if the personal data about you is a client’s privileged information.
- Right to Withdraw Consent you previously gave, when the legal basis of our processing is your consent.
- Right to Rectify inaccurate personal information we have concerning you and to have incomplete personal information completed.
- Right to Data Portability, that is, to receive the personal information that you provided to us, in a structured, commonly used, and machine-readable format. You have the right to transmit this data to another person or entity. Where technically feasible, you have the right to have your personal information transmitted directly from us to the person or entity you designate.
- Right to Object to our processing of your personal information based on our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or if we need to process such personal information for the establishment, exercise, or defense of legal claims.
- Right to Restrict us from processing your personal information (except for storing it): (a) if you contest the accuracy of the personal information (in which case the restriction applies only for a period enabling us to determine the accuracy of the personal information); (b) if the processing is unlawful and you prefer to restrict the processing of the personal information rather than requiring the deletion of such data by us; (c) if we no longer need the personal information for the purposes outlined in this Policy, but you require the personal information to establish, exercise, or defend legal claims; or (d) if you object to our processing based on our legitimate interest (in which case the restriction applies only for the period enabling us to determine whether our legitimate grounds for processing override yours).
- Right to be Forgotten. Under certain circumstances, such as when you object to our processing of your personal information based on our legitimate interest and there are no overriding legitimate grounds for the processing, you have the right to ask us to erase your personal information. However, notwithstanding such a request, we may still process your personal information if it is necessary to comply with our legal obligations, or for the establishment, exercise, or defense of legal claims. If you wish to exercise any of these rights, please contact us through the channels listed in this Policy.
When you contact us, we reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint with the supervisory authority in the Member State of your residence, place of work, or place of alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
If you are in the UK, you can lodge a complaint with the Information Commissioner’s Office (ICO) pursuant to the instructions provided here.
Additional information for individuals in Australia
In Australia, your personal information will be collected and held in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles under that Act.
How do we hold your personal information
We hold your personal information in a combination of electronic and hard copy files. Electronic information is stored with our third party data storage provider(s).
Access to and correction of your information
You have the right to request access to, and correction of, the personal information we hold about you.
To make a request, please contact us using the details set out in the “Contact us” section of this Policy. We may need to verify your identity before processing your request.
Making a complaint
If you believe we have breached the Australian Privacy Principles or otherwise mishandled your personal information, you may make a complaint by contacting us using the details set out in the “Contact us” section of this Policy.
If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
