Privacy policy

Last updated: April 23, 2025

This Privacy Policy describes how REFRAMD (the "Site", "we", "us", or "our") collects, uses, and discloses your personal information when you visit, use our services, or make a purchase from www.reframd.com (the "Site") or otherwise communicate with us regarding the Site (collectively, the "Services"). For purposes of this Privacy Policy, "you" and "your" means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy.

Please read this Privacy Policy carefully.

Changes to This Privacy Policy:
We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the "Last updated" date and take any other steps required by applicable law.

How We Collect and Use Your Personal Information:
To provide the Services, we collect and have collected over the past 12 months personal information about you from a variety of sources, as set out below. The information that we collect and use varies depending on how you interact with us.

In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide or improve the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

What Personal Information We Collect

Information We Collect Directly from You:
Information that you directly submit to us through our Services may include:

• Contact details including your name, address, phone number, and email.
• Order information including your name, billing address, shipping address, payment confirmation, email address, and phone number.
• Account information including your username, password, security questions and other information used for account security purposes.
• Shopping information including the items you view, put in your cart, saved into your account like loyalty points, reviews, referrals or gift cards, or purchases.
• Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services.

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

Information We Collect about Your Usage:
We may also automatically collect certain information about your interaction with the Services ("Usage Data"). To do this, we may use cookies, pixels and similar technologies ("Cookies"). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.

Information We Obtain from Third Parties:
We may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:

• Companies who support our Site and Services, such as Shopify.
• Our payment processors, who collect payment information to process your payment and fulfill your orders.
• Partners who help us run analytics or deliver marketing communications.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. Also see the section below, Third Party Websites and Links.

How We Use Your Personal Information:
We use your personal information to:

• Provide Products and Services
• Process payments and fulfill orders
• Communicate with you regarding your account and transactions
• Provide customer support
• Improve and personalize the Services
• Conduct analytics
• Promote security and prevent fraud
• Comply with legal obligations

Facial Data and TrueDepth API:
We do not collect or store facial data when users are simply using the app for virtual try-on purposes. Facial data is only collected when customers explicitly submit a facial scan to enable accurate eyewear size determination or to create a custom eyewear frame.

This data is securely stored only for the duration necessary to customize and produce the product, and for up to 30 days after the product has been delivered and the return period has expired. Customers may request deletion of their facial data at any time by contacting us at hello@reframd.com, particularly if they are satisfied with their product and do not intend to request a return or refund.

We do not share facial data or any personally identifiable information with third-party partners.

Cookies:
We use Cookies to power and improve our Site and Services. This includes remembering user preferences, conducting analytics, and enabling ad targeting. You can manage your preferences through browser settings. For more information on Cookies used by Shopify, visit Shopify's Cookie Policy.

Our website also recognizes the Global Privacy Control (GPC) signal, which enables you to opt-out of certain uses or disclosures of your information. Learn more at https://globalprivacycontrol.org/.

How We Disclose Personal Information:
We may share your information with:

• Vendors and service providers (e.g., for hosting, payment processing, shipping)
• Business partners (with your consent)
• Affiliates within our corporate group
• Government authorities when legally required
• Buyers in the event of a merger or acquisition

We do not use or disclose sensitive personal information without your consent or for the purposes of inferring characteristics about you.

User Generated Content:
Content submitted to public areas of our Services may be accessible to other users. We are not responsible for the use or misuse of such publicly available content.

Third Party Websites and Links:
Our Site may link to third-party sites. These sites are not governed by this Privacy Policy, and we are not responsible for their privacy practices.

Children's Data:
We do not knowingly collect information from children. If you believe a child has provided us with personal information, please contact us to request deletion.

Security and Retention of Your Information:
We implement reasonable security measures but cannot guarantee perfect security. We retain data only as long as necessary for the purposes outlined in this policy.

Your Rights:
Depending on your location, you may have the right to:

• Access, delete, correct, or transfer your personal data
• Opt out of certain uses of your data
• Restrict or object to processing
• Withdraw consent
• File a complaint with a data protection authority

To exercise these rights, contact us at hello@reframd.com.

International Users:
We may transfer and process your information outside of your country. When required, we use appropriate safeguards such as Standard Contractual Clauses.

Contact:
If you have any questions or wish to exercise your privacy rights, please contact us at:

Email: hello@reframd.com
Address: Schwedter Strasse 77, c/o J.A. Ngwenya, Berlin, 10437, DE

We are the data controller for your personal information unless stated otherwise.