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PRIVACY STATEMENT

EFFECTIVE DATE: JANUARY 2023

VSP Vision and its subsidiaries and affiliates (collectively, “VSP”) is
committed to protecting your personal information. This Privacy Statement
describes how VSP collects and uses the personal information you provide on, and
other information that is collected from, your use of our websites or any social
media page we maintain that contains a link to this Privacy Statement (the
"Sites") and through other interactions we may have with you. It also describes
the rights and choices you may have regarding our use and disclosure of your
personal information. California residents also refer to the below Supplemental
Notices to residents of those states.

For members and patients, please see our Notice of Privacy Practices for
information regarding our collection and use of your protected health
information ("PHI") pursuant to the U.S. Health Insurance Portability and
Accountability Act ("HIPAA").


COLLECTION AND PROCESSING OF PERSONAL INFORMATION

We collect and process personal information for our internal and Site-related
purposes, and in order to provide services (and in some cases to provide eyewear
or related goods) to our customers. We collect information from the following
categories of sources: directly from you, automatically (such as through cookies
and similar technologies on the Sites), VSP, from our affiliates, and through
your employer (in relation to business contact information).

GENERALLY:

 * Memberships. When you apply to become a member of a VSP insurance plan, we
   collect personal information from you in order to create and maintain records
   of the membership, comply with our regulatory and business obligations, and
   improve our business operations, among other things. Such information is
   handled by us in accordance with HIPAA as set forth in our Notice of Privacy
   Practices. 
 * Email subscriptions and text messaging. If you provide your email address and
   are on our email marketing list, we may send you email messages containing
   news and other updates relevant to our business. If you provide your mobile
   phone number, we may send text messages when permissible by law, with your
   consent.
 * Communications, reviews, and testimonials. You may choose to communicate with
   us through our Sites, or by email, phone, or regular mail, or you may provide
   us with reviews or testimonials about our products, on our Sites or
   otherwise. When you communicate with us or provide a review or testimonial,
   you may provide us with your name, content, and other contact details so that
   we can use your content (with your permission) and/or address your
   questions. 
 * Job applicants. If you apply for a job at VSP or its affiliates, you can find
   out more about how the personal information of applicants is managed here. 
 * Business contacts. We may receive your contact information, such as your
   personal identifiers (including your name, telephone number, and email
   address) and/or professional or business-related information (including your
   business address), through our online or offline interactions with you, such
   as when we work together on a project or discuss opportunities to work
   together. We may send you emails or call you with information about our
   business dealings, news, or marketing information to communicate with you for
   business purposes.
 * Social media. If you post information on a webpage we establish on a social
   media platform, we may use the information to respond, to promote our
   business and services, and in the normal course of our business operations.
   We may collect personal identifiers (such as your social media username) and
   other personal characteristics that you have made publicly available on the
   social media website. Note that the third-party operators of social media
   websites also receive such information, and their use of your personal
   information is governed by their own privacy policies.
 * Aggregate information. Aggregate, non-identifiable information may be
   collected during your experience on the Sites, and we use this information to
   analyze product or traffic data, resolve technical failures, enhance
   security, and test or improve accessibility to certain parts of the Sites. 
 * Automated data collection: Cookies and related technologies. VSP and our
   third-party partners, such as advertising partners and analytics providers,
   use cookies and similar tools across our Sites to improve performance and
   enhance your user experience. We may also use web beacons (i.e., tracking
   pixels) or other similar files that enable us to do the same thing. We use
   the term “cookies” in this Privacy Statement to refer to cookies and similar
   technologies that collect information in this way. Cookies may collect
   personal identifiers (such as your IP address) and Internet or other
   electronic network activity information, including information about your
   device (such as your browser characteristics, device IDs and characteristics,
   and operating system version) and information concerning your usage of our
   Sites (including the link you used to reach a given webpage). We use this
   information to determine how many users have visited particular webpages,
   viewed particular videos, or opened messages or alerts, and we may also use
   such information to improve the performance of the Sites, to improve our
   marketing activities, and to enforce our Site service terms and prevent
   malicious conduct.

In some cases, our third-party partners may process information collected by
cookies and related technologies that we permit them to use on the Sites. Please
see our Cookie Policy for more details.

We do not sell or share personal information, as those terms are used under
California law, except as set forth in our cookie disclosures. Please see our
Cookie Policy for information about the collection and use of personal
information by third parties who process information collected by cookies and
similar technologies that we permit them to use on the Sites.

OUR PROVISION OF EYEWEAR:

When you shop for or purchase eyewear and related goods, such as through
altaireyewear.com, eyeconic.com, and at our retail locations, VSP collects
personal information in order to create and maintain records of your purchases,
process your payment, comply with our regulatory and business obligations, and
improve our business operations. VSP may collect the following personal
information through its Sites or at store locations:

 * Personal identifiers, such as your name and email address;
 * Contact information, such as your shipping or mailing address and telephone
   number;
 * Payment information, such as your payment card information;
 * Transaction information, such as the eyewear or other goods you purchased;
   and
 * Health information (which may be considered "sensitive personal information"
   under certain U.S. state privacy laws).

Where applicable (for example, when we are providing services as a "business
associate"), this information is handled in accordance with HIPAA.

PROVIDERS:

If you are a provider in the VSP network or are in our Premier Program, VSP
collects the personal and other information you provide on our provider hub or
otherwise, and we use that information to provide services, comply with our
regulatory and business obligations, and improve our business operations. Any
PHI exchanged is handled in accordance with HIPAA.


INFORMATION WE DISCLOSE

We may disclose personal information described above for our business and
commercial purposes as described below.

 * Affiliates. We may share information, including personal information, with
   our affiliates in the VSP group of companies and any successors thereto in
   the normal course of our business operations, and for business purposes such
   as to communicate with you and to promote and provide our services. In this
   regard, personal information may be shared with one of our affiliates for use
   in providing a service to us.
 * Vendors and service providers. We share information, including personal
   information, with vendors and service providers that process such information
   to perform services for us in connection with the Sites, your purchases, or
   our other business operations.
 * Legal and similar disclosures. We may share personal information with law
   enforcement, the courts, our advisors, attorneys, and others who participate
   in the legal process, if we believe doing so is required or appropriate to:
   comply with legal requirements and law enforcement requests (such as a court
   order or subpoena); comply with legal process (such as discovery); or protect
   your, our, or others’ rights, property, or safety.
 * Merger, sale, or other asset transfers. If we are involved in a merger,
   acquisition, financing due diligence, reorganization, bankruptcy,
   receivership, sale of company assets, or transition of service to another
   provider, your personal information may be shared with the other parties and
   advisors involved under an obligation of confidentiality in connection with
   the negotiation of such transaction, and your personal information may be
   transferred as part of such a transaction (subject to compliance with
   applicable laws).
 * Do-not-sell and do-not-share disclosure and opt-out rights. Except as
   reflected in connection with our cookie disclosures, we do not sell your
   personal information for money or other consideration and we also do not
   rent, sell, or share “personal information” as defined by California Civil
   Code §1798.83 about you that we collect on the Sites with other people or
   unaffiliated companies for their direct marketing purposes. To opt-out of
   "selling" or "sharing" personal information (as defined by applicable law) in
   connection with cookies and similar technologies, please use the "Your
   Privacy Choices" link on our website homepage.


DATA PROTECTION AND SECURITY

We have implemented physical, electronic, and administrative procedures in an
attempt to safeguard and prevent unauthorized access and maintain data security
of the information we collect. Please note that there is risk involved in using
the Internet and that certain aspects of Internet communications are inherently
not completely secure. We therefore recommend that you use every precaution to
protect your information when using the Internet and any other links. 


HOW YOU CAN OPT-OUT OF MARKETING EMAILS AND TEXT MESSAGES

If you have a VSP account, you may control your information and preferences for
receiving electronic and marketing information, including opt-in or opt-out
selections for certain programs and interests through your account. For
marketing emails, you may use unsubscribe functionality and information provided
on those emails. If you wish to stop receiving text updates from VSP, you can
respond “STOP” to be opted out.  


PRIVACY RIGHTS

Certain jurisdictions have specific legal requirements and grant privacy rights
with respect to personal information, and we will comply with restrictions and
any requests you submit as required by applicable law. For example, you may have
the right to review, correct, and delete personal information we have about you,
or to consent or withdraw consent to certain uses or sharing of personal
information. You also have the right to not be discriminated against for
exercising your privacy rights. If you are a California resident, see our
Supplemental Notice to California Residents section below. If you otherwise seek
to exercise your rights under the law of another jurisdiction, please contact us
by emailing privacy@vsp.com.

Please note that, when you make a request, we may require that you provide
information and follow procedures so that we can verify your identity (and the
applicable jurisdiction). The verification steps we take may differ depending on
your jurisdiction and the request. Where possible, we will attempt to match the
information that you provide in your request to information we already have on
file to verify your identity. If we cannot verify your request, we may ask you
for additional information to help us do so.

We will respond to your request within the time period required by applicable
law. However, we may not always be able or required to comply with your request,
in whole or in part, and we will notify you in that event.


LINKS TO THIRD PARTY WEBSITES

The Sites may contain links to third-party websites. This Privacy Statement does
not apply to the practices of such other websites, and we are not responsible
for the actions and privacy policies of the third parties that operate or
interact with those websites.


NOT FOR USE BY CHILDREN

The Sites are not intended for use by children. In particular, if you are under
the age of 16, you may not use our Sites. We do not knowingly collect, maintain,
or use personal information from children under 16 years old. If we believe that
any information has been posted by a child under the age of 16, we will promptly
delete that information. Parents may contact us using the methods set forth
below to request that any information collected online concerning their child be
removed from our records.


CHANGES TO THIS PRIVACY STATEMENT 

VSP may change this Privacy Statement from time to time, and the revised version
will be effective when it is posted and will apply to personal information
received after that date. If we make any material changes, we will provide
notice of such changes by updating this page or by posting the notice on another
pertinent location where this Privacy Statement may be posted for a reasonable
period of time (which we estimate will be approximately two weeks). We encourage
you to review this Privacy Statement periodically, especially if you don’t visit
the Sites regularly.


CONTACT US

If you have a question or concern about this Privacy Statement or how we handle
your personal information, contact the Privacy Office at the address listed
below, or email our Chief Privacy Officer at Privacy@vsp.com.

VSP Privacy Office Address: 3333 Quality Dr., Rancho Cordova CA 95670 Email:
Privacy@vsp.com Phone: 916-858-7432 or 800-877-7195

 


SUPPLEMENTAL NOTICE TO CALIFORNIA RESIDENTS 

This Supplemental Notice to California Residents section applies only to
personal information of consumers who are California residents. Consistent with
the California Consumer Privacy Act, as amended by the California Privacy Rights
Act (collectively, the "CCPA"), we will honor a California consumer’s request:
for additional information about our data collection, use, disclosure, and
sharing practices in connection with the consumer’s personal information; for
the specific personal information collected about the consumer during the
previous 12 months; for the deletion of the personal information we have about
the consumer; to restrict certain processing of sensitive personal information;
or for correction of inaccurate information. A California consumer will not be
discriminated against for exercising the consumer’s California privacy rights.
Please note, the CCPA does not govern protected health information (PHI). For
information on your rights under HIPAA, please see our Notice of Privacy
Practices.

Exercising Your Rights: California consumers may use an authorized agent to make
privacy rights requests. We require the authorized agent to provide us with
proof of the California consumer’s written permission (for example, a power of
attorney) that demonstrates authorization to submit a request for the California
consumer. An authorized agent must follow the process described below to make a
request, and we will also (a) require the authorized agent to verify the agent’s
own identity and (b) confirm the agent’s authority with the California consumer
about whom the request was made.

California consumers can exercise any of the rights as described in this section
of the Privacy Statement by submitting a request on our Data Subject Request
Form, emailing us at Privacy@vsp.com, or calling 1-800-877-7195. In most cases,
you will be required to provide your name and email address so that we can
verify your request, and in some cases additional information may be required.
Except as described in this Privacy Statement or provided for under applicable
privacy laws, there is no charge for a California consumer to exercise their
legal rights.

We do not sell or share personal information, as those terms are used under the
CCPA, except as set forth in our cookie disclosures. Please see our Cookie
Policy for information about the collection and use of personal information by
third parties who process information collected by cookies and similar
technologies that we permit them to use on the Sites.

Except for information collection and processing as described previously, we do
not collect any “sensitive personal information” as defined by the CCPA.

We use the following criteria to determine the length of time for which we
retain personal information subject to this Privacy Statement:

 * the purposes for which the personal information is used, and the length of
   time for which such information is required to achieve those purposes,
   including for business operations, security purposes, and legal requirements;
 * whether we are required to retain the category of personal information in
   order to: (i) comply with legal or contractual obligations; (ii) assert or
   defend against potential legal claims or as necessary to investigate theft,
   fraud, or other activities that are potentially (a) in violation of our
   policies and procedures applicable to you or (b) a violation of the law;
   (iii) ensure a secure online environment; and/or (iv) protect health and
   safety;
 * the privacy impact on the consumer of ongoing retention; and
 * the manner in which the personal information is maintained and flows through
   our systems and how best to manage the lifecycle of such information in light
   of the volume and complexity of the systems in our infrastructure and the
   need to maintain high integrity and availability within our systems.

In addition, we delete personal information if a California consumer
appropriately invokes the right to delete as to such personal information and no
exception applies.

 



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