Australia and New Zealand Privacy Notice 

Addendum to the Solos Privacy Policy for Australian and New Zealand Users

 

If you are in Australia or New Zealand, the following provisions apply to you and override any inconsistent terms in our Privacy Policy.

 

This Addendum is to be read together with the Solos Privacy Policy (https://solosglasses.com/pages/privacy-policy) and applies to our Site, App and device features (including microphones and, where applicable, camera‑enabled frames). If there is any inconsistency, this Addendum prevails for Australian and New Zealand users.

1.        Applicable Law

Australia: We handle your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

 

New Zealand: We handle your personal information in accordance with the Privacy Act 2020 and the Information Privacy Principles (IPPs).

 

2.        Collection of Personal Information 

We collect personal information directly from you (for example, when you place an order, create an account, register a warranty, contact support, subscribe to marketing communications) and where you enable features in the products or app, automatically through your use of our website, app and device features.

 

Where we handle health information or sensitive information, additional protections under Australian privacy law apply (see Section 2).

 

The types of personal information we collect may include (as relevant to your interactions with us):

• Identity and contact details: full name, email address, postal/shipping address, phone number.
• Account and transaction: account credentials, order and warranty details, payment token information processed by payment providers, and customer support records.
• Optical prescription information, including images of prescriptions, and other related health information which you may provide to fulfil orders (treated as sensitive information in Australia).
• Device and app data: device identifiers, app usage and settings, geolocation (where enabled), logs and diagnostics.
• Audio content: voice/audio captured by the microphone in our frames when enabled, and any transcripts/translations generated by the app/AI features (e.g., SolosTranslate/ SolosChat).
• Image/video content (camera‑enabled frames only): photos or videos captured when the camera feature is enabled.
• Marketing preferences and communications history.

Where we collect health information (including optical prescriptions) or biometric information (if applicable), we will only collect this with your consent or as otherwise permitted by law, and we will apply enhanced protections consistent with the APPs.

 

Why We Collect Your Information: 

• Process and fulfil orders 
• Provide customer support and warranty services 
• Deliver products, services, and information 
• Improve our products and customer experience 
• Communicate with you 
• Comply with legal obligations 

Consequences of Not Providing Information

If you choose not to provide certain personal information, we may not be able to:

• Process your order
• Deliver products, services and information 
• Provide warranty services 
• Respond to your enquiries 

Where collection is required by law, we will notify you at the time of collection. For information about access and correction, please see Section 6 of this Addendum and Section 6 of our Privacy Policy.

New Zealand – Indirect collection of personal information (IPP 3A)

Where we indirectly collect personal information (for example, bystander audio picked up by the microphone or images captured by camera‑enabled frames) we will take reasonable steps where possible to ensure affected individuals are made aware.

3.        Cross-Border Disclosure of Personal Information

Your personal information may be stored, processed, or disclosed outside your country of residence, including to our related entities, cloud hosting providers, payment processors, logistic providers, and customer support providers located in: 

• Singapore
• Japan
• Germany (EU)
• United States

Australian Users (APP 8)

Where we disclose personal information to overseas recipients, we take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information.

In some circumstances, an exception under APP 8 may apply. If we intend to disclose information to an overseas recipient without comparable protections, we will seek your express consent prior to any such disclosure.

New Zealand Users (IPP 12) 

Before disclosing personal information to a foreign entity, we take reasonable steps to ensure that the recipient:

 

     Is subject to privacy laws that provide comparable safeguards to the Privacy Act 2020; or

• Is contractually required to protect your information in a way that provides comparable safeguards; or
• Otherwise meets the requirements of IPP 12. 

If we rely on your express authorization to disclose your information to a foreign entity that does not provide comparable safeguards, we will clearly inform you of this and obtain your authorization before the disclosure occurs.

4.        Data Security

We take reasonable technical and organizational steps to protect your personal information from misuse, interference, loss, unauthorized access, modification, or disclosure. These steps include technical and organisational controls appropriate to the risk, such as encryption in transit/at rest (where applicable), access controls, logging/monitoring, and secure development practices, and requiring our service providers to meet comparable standards.

5.        Data Retention

We retain personal information only as long as reasonably necessary to: 

• Fulfil the purposes for which it was collected;
• Comply with legal, tax, and accounting obligations; and
• Resolve disputes and enforce agreements. 

When information is no longer required, we take reasonable steps to destroy or de-identify it.

6.        Access and Correction

You have the right to request access to personal information we hold about you and to request correction if it is inaccurate, out of date, incomplete, irrelevant, or misleading.

Response Times

• Australia: We will respond within a reasonable period (generally within 30 days)
• New Zealand: We will respond within 20 working days, unless an extension is permitted under law.

Fees

We will not charge you for making a request. We may charge a reasonable administrative fee for providing access where permitted by law.

 

Refusal 

If we refuse access or correction, we will provide written notice explaining the reasons and the complaint mechanisms available to you.

 

7.        Anonymity and Pseudonymity

Where lawful and practicable, you may deal with us anonymously or by using a pseudonym (for example, when making general enquiries). However, for most services - including processing orders or warranty claims — we require your identity to provide those services.

8.        Direct Marketing and Electronic Messages

We may send you marketing communications from time to time where permitted by law. You can opt out at any time using the unsubscribe link in those communications or by contacting us directly. Any such communications are sent in compliance with the Australian Spam Act 2003 and the New Zealand Unsolicited Electronic Messages Act 2007 (as applicable).

9.        Use of Recording Features

When you enable recording features (microphone or camera), you are responsible for complying with local laws that may regulate audio/video recording or require consent from people being recorded.

10.   Complaints

If you wish to make a privacy related complaint, contact us at: cs@solosglasses.com

We will investigate your complaint and respond in writing within a reasonable time.

If you are not satisfied with our response, you may lodge a complaint with the relevant regulator:

 

Australia: 

Office of the Australian Information Commissioner

Website: www.oaic.gov.au

Phone: 1300 363 992

 

New Zealand:

Office of the Privacy Commissioner

Website: www.privacy.org.nz

Phone: 0800 803 909