BASIC INFORMATION ON DATA PROTECTION

• Controller: REFLECT EYEWEAR SL

• Purpose: We use your data, among other purposes, to manage the purchase of products and services, respond to your inquiries, and, where applicable, send you personalized communications.

• Lawful basis: The lawful basis for processing your data lies primarily in your consent and the proper execution of the contractual relationship with REFLECT EYEWEAR SL.

• Recipients: Your data will be processed by other companies within the Group and third-party partners who collaborate with us.

• Rights: You have the right to access, rectify, erase, object to, restrict, and request the portability of your personal data.

• Additional information: You can find more detailed information about how we handle your personal data and your rights in the full Privacy Policy below, as well as in our Cookie Policy.

ADDITIONAL INFORMATION ON DATA PROTECTION

REFLECT EYEWEAR SL (hereinafter, “the Company”), as the data controller, undertakes to adopt the necessary technical and organizational measures to ensure that the processing of your data complies with the provisions of Regulation (EU) 2016/679 (“GDPR”) and Organic Law 3/2018.

The Company processes your personal data lawfully and fairly, ensuring that it receives adequate protection and is not misused. Furthermore, the Company aims to be transparent in managing the personal data of its customers and users, providing all necessary information regarding the collection and processing of such data.

The purpose of this Privacy Policy is to inform you about who processes your personal data, why we collect it, how long we retain it, with whom we share it, and what your rights are in this regard.

By providing your personal information and using our Website, you acknowledge that you have read and understood the personal data protection information set out in this Privacy Policy and in the Cookie Policy.

A. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

The Controller of your personal data is:

Company name: REFLECT EYEWEAR SL

Tax ID (CIF): B67409912

Telephone: +34 936 398 209

Postal address: Calle Bertran 107, bajos derecha (08023) Barcelona

Email: info@visionarioleparc.com

B. FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

Depending on the products, services, or features requested, the Company may need to process different types of data, generally including:

• Identification and contact details: name, surname, phone number, postal address, email, among others;

• Data related to the execution of a sales or service contract with the Company: identification and contact details, payment information, purchase, order, and return data, among others;

• Data collected automatically: when interacting with our Website, certain browsing data are automatically collected through cookies, as detailed in the Company’s Cookie Policy;

• Data about your preferences and interests.

Automatically collected data may include your use of the Website and the devices you use to access and interact with it. This may involve: your device’s IP address, browser type, operating system, date and time of Website access, referring website, geolocation data, pages visited on the Website, and time spent on each page.

Personal data are processed for the following purposes:

• To manage the purchase of products and services offered by the Company: to provide you with the requested products or services, operate our business internally (accounting, auditing, and internal processes), and manage payment;

• Quality analysis: to conduct customer and user satisfaction surveys regarding the quality of our products and services;

• Customer service: to handle and respond to your requests, inquiries, and complaints;

• Advertising and marketing activities: including personalization of services and recommendations based on your interaction with the Company (e.g., purchase and browsing history). If you give your consent, we will use your data to periodically send information about new products and promotions that may interest you;

• To improve user experience on the Website: to perform analytical and statistical studies on how users browse the Company’s Website.

C. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR DATA?

The legal basis depends on the purpose for which we process your data, as detailed below:

• Managing product and service purchases: Processing is necessary for the correct performance of the contractual relationship with the Company. It is also based on your consent (when you choose to purchase our products or services) and the Company’s legitimate interest in verifying and preventing potential fraud and ensuring security.

• Quality analysis: Based on the Company’s legitimate interest in assessing customer satisfaction to improve products and services.

• Customer service: Based on the Company’s legitimate interest in responding to your requests and resolving incidents. When dealing with claims or product/service issues, processing is necessary for compliance with contractual obligations. For data protection–related requests, processing is necessary for compliance with legal obligations.

• Advertising and marketing activities: Based on your consent to receive commercial (possibly personalized) communications, and on the Company’s legitimate interest in sending similar information about products or services previously purchased or of demonstrated interest.

You may withdraw your consent at any time.

• Improving user experience: Based on the Company’s legitimate interest in analyzing and enhancing the quality of our services.

D. HOW LONG WILL WE KEEP YOUR DATA?

Your personal data will be retained only as long as necessary for the purpose for which they were collected.

They will be securely stored, with appropriate measures to ensure accuracy and integrity, for as long as processing is required or until you exercise your right to deletion or restriction.

After that, your data will be blocked and kept only for legally required periods to address potential liabilities and demonstrate compliance with legal and contractual obligations. Once those periods expire, your personal data will be permanently deleted.

E. WITH WHOM DO WE SHARE YOUR DATA?

Your personal data will be processed by Company personnel bound by confidentiality and proper data management obligations.

To fulfill the purposes set out in this Privacy Policy, the Company may share your personal data with other Group companies and with the following third parties:

• Logistics, transport, and delivery service providers, and/or associated establishments;

• Customer service providers;

• Marketing and advertising partners;

• Public authorities or agencies to comply with legal requirements, judicial orders, investigations, or to handle legal liabilities, prevent unlawful use of the Website, respond to third-party claims, or prevent and investigate fraud.

These third parties only have access to the personal data necessary to perform their services and are required not to use it for any other purpose. The Company also requires these third parties to maintain the same level of protection and confidentiality applied to your data. All are bound by data processing agreements with the Company.

F. WHAT ARE YOUR RIGHTS?

You are entitled to exercise the following rights under data protection law:

• Access (Art. 15 GDPR): to obtain information about the purposes of processing, data categories, recipients, etc.

• Rectification (Art. 16 GDPR): to request modification of inaccurate or incomplete personal data.

• Erasure (Art. 17 GDPR): to request deletion of your personal data when:

• the data are no longer necessary for their original purpose;

• processing is based on consent and you withdraw it;

• you object to processing and there are no overriding legitimate grounds;

• data have been unlawfully processed;

• data must be erased for compliance with legal obligations;

• data were collected in relation to information society services.

• Restriction (Art. 18 GDPR): to request limitation of processing when:

• you contest the accuracy of your data;

• processing is unlawful and you oppose erasure;

• the Company no longer needs your data but you need them for legal claims;

• you have objected and verification of legitimate grounds is pending.

• Portability (Art. 20 GDPR): to receive your data or have them transmitted to another controller, when processing is based on consent or contract and carried out by automated means.

• Objection (Art. 21 GDPR): to object to processing based on public or legitimate interest.

• Objection to automated processing (Art. 22 GDPR): to not be subject to automated decisions, including profiling, that produce legal or significant effects.

G. HOW CAN YOU EXERCISE YOUR RIGHTS?

You can exercise your data protection rights through the following means:

• By sending a written and signed request to the Company (Calle Bertran 107, bajos derecha, 08023 Barcelona), indicating the reason for your request and the right you wish to exercise, along with a photocopy of your ID or equivalent proof of identity;

• By sending a completed and signed form, together with a photocopy of your ID or equivalent document, to: info@visionarioleparc.com

Below are the official forms to exercise each right:

• Right of access: Link

• Right of rectification: Link

• Right of erasure: Link

• Right to restriction: Link

• Right to portability: Link

• Right of objection: Link

• Right to object to automated processing: Link

You also have the right to file a complaint with the competent data protection authority: the Spanish Data Protection Agency (AEPD) — Complaint Form.