PRIVACY AND COOKIE POLICY

This Privacy and Cookie Policy (this “Policy”) describes how Marchon Eyewear Inc. (“Marchon” or “we”) collects and processes your personal information. By using the marchon.com, mymarchon.com or other websites operated by Marchon or its affiliated companies such as the dragonalliance.com, flexon.com or those of its other house brands (each, a “website”) or by submitting your personal information to Marchon, you acknowledge that you have read and understood, and agree to the use of your personal information by Marchon in accordance with this Policy. We reserve the right to revise this Policy or any part of it from time to time. Please review the Policy periodically for changes.

What personal information we collect and why?
Marchon collects the personal information it needs to provide services and information to customers and for its business operations. If you choose not to provide certain personal information to us, we may not be able to provide you with the services you require or otherwise access certain parts or functions of our website.

The following are the main purposes for which and when we collect your personal information when visiting the website:

• When you access and use the website - When you access and browse the website, certain information may be passively collected as further explained in this Policy (please see “How we collect personal information”).
• When you enroll in our services - When you obtain a service, download materials, subscribe to or participate in certain Marchon programs, promotions or contests, Marchon may require you to create a user account and maintain a user profile or otherwise enter your personal details. You may control your preferences for using the website, or for receiving electronic and marketing information, including opt-in or opt-out of certain programs and interests. You can access your user profile at any time to change your preferences or make other modifications.
• To assist with your queries - You may also choose to provide us with your name or other contact details when you contact us using our website so that we can respond to your requests for information about Marchon’s products or services or that of its affiliates or business partners.
• If you are one of our business partners - As a business partner with a registered user account, we collect your contact information and other relevant information to provide you with products and services you request or purchase from us. We also make some of this information available on this website so that our customers are able to find points of sale within our network.

HOW WE COLLECT PERSONAL INFORMATION

(i) Active collection
Active collection with respect to the information that you disclose to Marchon when you visit the website may include your name, company name, job title, home and business address, email address, telephone number, mobile number or other contact information, and demographic information such as your gender, postal code, country, preferences, as well as username and password, or delivery and fulfillment information as may be necessary, and such other personal information that Marchon may request and you elect to disclose to Marchon from time to time. We ask that you not send us, and you not disclose, any sensitive personal information such as health related information. If, contrary to this request, you do provide any sensitive information, in doing so you expressly consent to us collecting and handling that sensitive information in accordance with this Policy.

(ii) Passive collection
Passive collection through the use of cookies and similar tools of certain technical data such as your Login, your IP-address (the unique numbers which identify the network and device you are using) and date and time of sign in. Marchon also passively collects how you use the website and services, for example, what areas you access, what content you browse or download, what services you access and for how long.

How we use personal information?
We generally use your personal information for the purposes described in this Policy, and for related purposes insofar not incompatible with the stated purposes (or otherwise as required or authorized by law).
We may use the data that is passively collected for the purposes of determining effective click-path flow and to manage the website, resolve technical failures, testing or improving accessibility to certain parts of the website allowing us to ensure that you can reach the information on the website quickly and easily.
Further, we may use passively collected data for the purpose of market and product analysis and to improve user experience through collecting aggregate or statistical review of user site traffic patterns.
Passively collected information does not identify you to Marchon by name, and Marchon does not link your IP-address to you or to any personally identifiable information.
If you have agreed or asked, we may also use your personal information to keep you up to date with information about our products and services or those of our affiliates or business partners or to provide you with special notices. We will not contact you by telephone, fax, or other means unless you have explicitly requested us to contact you in that manner. If you do not want us to use your personal information in this way or send you any further information, you can always let us know by contacting us through the contact details given below.
All recipients of personal information will be required to keep the personal information secure, and a data recipient that qualifies as a data processor will be required to process the personal information only in accordance with our instructions.

DISCLOSURES AND DATA TRANSFER
Marchon may disclose and transfer your personal information to IT providers, subcontractors and other third party service providers that assist with the operation of the website, or with the delivery of products, provision of services, or the performance of associated activities.
We may disclose your personal information to law enforcement authorities or other government officials, only when required by law (including applicable Freedom of Information or similar law) or by legal process, when necessary to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraud or illegal activity.
We may also disclose and transfer your personal information, subject to the requirements of applicable law and as necessary or appropriate, to protect the security of the website, to protect Marchon, its subsidiaries, directors, officers, and employees or other parties, or in connection with the sale or transfer of all or part of the business of Marchon.
Because Marchon is part of a global group of companies, personal information that you submit to us may be transferred, accessed and stored globally, as necessary for the provision of the products and services, and for the reasonable conduct of our business operations and activities. Some recipients of the personal information may be located within your home jurisdiction or elsewhere, including countries that do not offer an adequate level of protection within the meaning of the European Data Protection Directive (95/46/EC). Marchon will ensure that the data recipient adequately safeguards the personal information.
By providing your personal information to us, you consent to the disclosure of your personal information outside your jurisdiction and overseas.

THE USE OF COOKIES
We use cookies and similar tools across our website to improve its performance and enhance your user experience. Cookies are small, alphanumeric identifiers that are transferred to your computer or mobile device when you first visit our website. Cookies enable the website to recognize your computer or device upon your next visit of the website, analyze how well our website is performing and to provide personalized features. Marchon may also use web beacons (i.e. tracking pixels) or other similar files that enable to do the same thing. Marchon uses the term “cookies” in this Policy to refer to all files that collect information in this way.

What type of cookies do we use?
Essential cookies
Some cookies used are essential for the operation of the website. These cookies are so-called essential cookies. For example, some cookies allow us to identify registered users and ensure they can access their user accounts or use other requested services, like shopping baskets or e-billing. Without these cookies, those services cannot be provided. Most of the essential cookies used on the website are session cookies. Session cookies are deleted from your computer or device upon closing your browser session.

Functionality cookies
Functionality cookies allow us to remember your preferences. Users can choose to have their User ID retained by checking the box next to “Remember my User ID” in the sign-on field. By doing so, a cookie will be saved on the computer’s hard drive allowing the User ID to automatically populate the sign-on field each time you return to the page and to recall your customization preferences when you log in. The functional cookies used by Marchon are exclusive to the website and cannot be obtained or read by other websites. The functionality cookies used on this website are persistent cookies. Persistent cookies remain stored on your computer or device until you delete them manually or until they expire.

Performance cookies
Marchon will collect data about your activities when visiting the website. This information may include the content you view, the date and time you are viewing this content, the products you purchase, or your location information associated with the user’s IP address. These cookies are so called performance cookies and do not collect any information that could identify you. All information these cookies collect is aggregated and therefore anonymous and is only used to help us improve how our website works, understand your interests and measure how effective our content is. The performance cookies used on the website are either session or persistent cookies.

Behaviourally targeted advertising cookies
Marchon uses technologies such as cookies and pixels to keep track of your activities on our website and that of its affiliated companies and may use those cookies to serve you more relevant advertisements in respect of our products. We do not track your interaction with unaffiliated websites nor do we share your personal data with any of our advertisers. The advertisement cookie used on the website is a persistent cookie. If you have agreed or asked, we may also use your personal information to keep you up to date with information about our products and services or those of our affiliates or business partners or to provide you with special notices. We will not contact you by telephone, fax, or other means unless you have explicitly requested us to contact you in that manner. If you do not want us to use your personal information in this way or send you any further information, you can always let us know by contacting us through the contact details given below.

All recipients of personal information will be required to keep the personal information secure, and a data recipient that qualifies as a data processor will be required to process the personal information only in accordance with our instructions.

Third party cookies
Marchon uses third-party cookies, which are cookies that are set by a domain other than that of this website. If you visit the website and another entity sets a cookie through the website, this would be a third-party cookie.
Marchon uses the following third party cookies:

For more information on the applicable policies for the use of the third party cookies, please visit:
Google Analytics Privacy Policy
Google Analytics Cookie Usage

Is it possible to block the use of cookies?
You can withdraw your consent at any time by deleting the cookies using your internet browser settings. The Help portion of the toolbar on most browsers will tell a user how to prevent the browser from accepting new cookies, provide notification if new cookies are received, or disable cookies altogether. Please note that if you use your browser settings to block all cookies, you may not be able to access all or parts of the website.
If you are based in the European Union and would like to learn more about cookies or to choose not to receive them, please visit www.youronlinechoices.eu or www.allaboutcookies.org. If you are based in the United States and would like to learn more, please visit http://www.aboutads.info/choices.

How secure is your personal information?
Pursuant to applicable laws and regulations, Marchon maintains appropriate technical and organization measures to protect your personal information against accidental or unlawful destruction or loss, alteration, unauthorized disclosure or access.

Links to unaffiliated websites
Our website contains links to unaffiliated websites. We are not responsible or liable for the privacy practices or the content of such unaffiliated websites. The privacy policies applicable to such other websites may differ substantially from this Policy, so we advise you to read them before using those unaffiliated websites.

Public Forums
We may make chat rooms, forums, message boards and news groups available to website users at various times. Please remember that, unless otherwise stated, any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information in these areas.

Access, correction and opting out
If want to exercise your right to see a copy of the information that we hold about you, or think that information we hold about you may need to be corrected, want to delete all or any part of it or to object to the processing on legitimate grounds, please contact us with enquiry topic “Data privacy”, or alternatively send a signed letter to the address listed below. See the About Us section of our website for information on our offices worldwide. Marchon will make every reasonable effort to promptly comply with your request. Marchon may, however, limit access to your personal information where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by international standards. To protect your privacy and security, Marchon may take reasonable steps to verify your identify before responding to your request.
You may always opt out of receiving future communications from Marchon by contacting us through the contact details given below. We aim to remove you from the subscriber list within ten (10) business days from receipt of your request.

More information?
If you have any queries or would like further information about our privacy policies or practices, or would like to tell us that you do not want us to use your personal information to contact you with our newsletter or with information about products or services, please contact the Marchon Customer Service at:

Marchon Eyewear Inc.
201 Old Country Road
Melville, NY 11747

Email: cs@marchon.com
Phone: 1.800.645.1300 (U.S. only)

Visiting www.marchon.com and using the Contact Us form (only if available).

Created: May 2016