Privacy Policy

Privacy Policy

Last Updated: May 29, 2026

At AvilaDubee ("AvilaDubee," "we," "us," or "our"), we respect your privacy and are committed to protecting your personal information.
This Privacy Policy describes how Adele International Trading Co., Limited ("Company"), the operator and data controller of this website, collects, uses, stores, shares, and protects your personal information when you visit, browse, interact with, or purchase sunglasses and non-prescription plano eyewear products from our website (the "Site").
By accessing or using our Site, you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

We may collect personal information directly from you, automatically through your use of the Site, from virtual try-on functionality, and from trusted third-party service providers.

1.1 Information You Provide

When you place an order, contact us, subscribe to our newsletter, or otherwise interact with our Site, we may collect:
  • Full name
  • Billing address
  • Shipping address
  • Email address
  • Phone number
  • Order details
  • Customer service communications
  • Payment-related information
Payment information is processed securely by our payment service providers. We do not store complete credit card information on our servers.

1.2 Automatically Collected Website & Device Information

When you visit our Site, we may automatically collect:
  • IP address
  • Browser type and version
  • Device information
  • Operating system
  • Time zone
  • Referral source
  • Pages viewed
  • Product interactions
  • Website navigation behavior
  • Advertising interaction data
This information helps us improve website performance, security, and user experience.

1.3 Facial & Biometric Data from Virtual Try-On Tool

We offer an augmented reality Virtual Try-On feature that uses your device camera to capture temporary facial landmarks and facial geometry for the sole purpose of overlaying our sunglasses and plano frames onto your face for visual preview. This data may qualify as sensitive biometric information under Illinois, Texas, California, and other U.S. state privacy laws. Key rules for facial data:
  1. Facial scan data is only processed in real-time during your active try-on session.
  2. No raw facial photographs, facial templates, or permanent biometric identifiers are saved to our servers or your user account after you close the try-on tool or browser tab. All facial image data is automatically erased immediately after your session ends.
  3. We never use facial data for identity recognition, user tracking, targeted advertising, or third-party profiling.
  4. We do not sell, rent, or share any facial or biometric try-on data with advertisers, analytics partners, or any external third parties.
  5. You may disable camera access to the Virtual Try-On tool at any time via your device browser or phone settings.

2. Cookies and Tracking Technologies

We use cookies and similar technologies, including:
  • Cookies
  • Pixels
  • Web Beacons
  • Tags
  • Local Storage Technologies
These technologies help us operate our website, understand user behavior, improve performance, and deliver relevant advertising.

Types of Cookies We Use

Strictly Necessary Cookies

Required for website functionality, security, checkout, and fraud prevention. Cannot be disabled if you wish to complete purchases.

Analytics Cookies

Help us understand how visitors use our website.

Examples include:
  • Google Analytics
  • Shopify Analytics

Advertising Cookies

Used to measure advertising effectiveness and deliver personalized advertising.

Examples include:
  • Google Ads
  • Google Remarketing
  • Google Conversion Tracking
For visitors located in jurisdictions requiring consent, non-essential cookies are only activated after obtaining your consent through our cookie consent banner.

You may manage cookie preferences through your browser settings.

3. How We Use Your Information

We may use your information to:
  • Process and fulfill orders for sunglasses and non-prescription plano glasses
  • Provide customer support
  • Communicate order shipping and tracking updates
  • Verify transactions and payment identity
  • Prevent fraud, chargebacks, and abusive orders
  • Improve website performance and virtual try-on functionality
  • Analyze website visitor usage trends
  • Conduct internal business operations and inventory management
  • Comply with all applicable legal and tax obligations
  • Send opt-in promotional marketing communications where permitted by law
  • Measure cross-platform advertising campaign performance
  • Deliver personalized product recommendations and targeted advertising
You may unsubscribe from marketing emails at any time via the footer unsubscribe link in all promotional emails.

4. Legal Basis for Processing (EEA Visitors)

For visitors located in the European Economic Area (EEA), United Kingdom, or similar jurisdictions, we process personal data under one or more of the following legal bases:
  • Performance of a sales contract between you and AvilaDubee
  • Compliance with legal, tax, and customs obligations
  • Our legitimate business interests in operating an eyewear e-commerce store
  • Your explicit consent for marketing, cookie tracking, and virtual try-on camera access
Where consent is required, you may withdraw consent at any time by adjusting browser settings, unsubscribing from emails, or contacting our support team.

5. Google Ads, Analytics, and Advertising Services

We use Google services to better understand customer shopping behavior and optimize our global advertising efforts.

These services may collect information about:
  • Website visits
  • Sunglasses & plano frame product views
  • Shopping cart and checkout behavior
  • Advertising click interactions
  • Order conversion events
Google may use cookies and similar tracking technologies to provide analytics and personalized advertising services.

For more information, please review Google's official Privacy Policy:

https://policies.google.com/privacy

You may manage Google personalized advertising preferences through:

https://adssettings.google.com

6. Sharing of Personal Information

We do not sell your personal information for direct monetary compensation.

However, certain cross-site targeted advertising activities may be defined as "sharing" under U.S. state privacy laws including CCPA/CPRA, Colorado CPA, Oregon OCPA, and Minnesota MCDPA.
We may share limited necessary personal information only with the following trusted service providers, all bound by strict data confidentiality agreements:
  • Shopify (website hosting, store operations)
  • Shopify Payments, PayPal (secure payment processing)
  • Google Analytics, Google Ads (analytics & advertising)
  • Global shipping carriers (order delivery fulfillment)
  • Fraud prevention & chargeback risk providers
  • Third-party customer support platform vendors
These providers may only use your personal information as strictly necessary to perform contracted services on our behalf, and are prohibited from reusing your data for their own independent marketing purposes.

7. Additional U.S. State Resident Privacy Rights

This section covers mandatory disclosures for residents of California, Colorado, Oregon, Minnesota, Delaware, Maryland, New Jersey, Texas, and Virginia, as required by each state’s consumer privacy laws. Washington state residents may also review our separate Washington Consumer Health Data Privacy Policy for supplementary disclosures related to health and wellness browsing activity.

7.1 California Privacy Rights (CCPA/CPRA)

If you are a California resident, you may exercise the following legal rights:
  1. Right to Know: Request full disclosure of all categories of personal information we collect about you, sources of collection, and third parties we share data with.
  2. Right to Access: Receive a portable copy of all personal data stored under your customer profile.
  3. Right to Correction: Request edits to inaccurate or incomplete personal information.
  4. Right to Delete: Request permanent deletion of your customer account and all associated personal data, subject to legal retention exceptions for tax, accounting, and fraud prevention records.
  5. Right to Opt Out: Opt out of all sale or sharing of your personal information for targeted cross-context advertising.
  6. Right to Limit Sensitive Data Use: Request limits on how we use sensitive personal data where applicable.
  7. Non-Discrimination Protection: We will not charge higher prices, withhold services, or discriminate against you for exercising any privacy rights.

7.2 Colorado, Oregon, Minnesota, Texas, Virginia Resident Additional Rights

Residents of these states hold identical access, correction, deletion, data portability, and targeted advertising opt-out rights as California consumers. Additional unique provisions:
  • Oregon & Minnesota residents may request a full list of specific third-party entities we have shared your personal data with.
  • Colorado residents have the right to submit a formal appeal if we deny your privacy rights request.
  • Texas residents hold expanded rights to restrict processing of sensitive biometric facial data collected from our Virtual Try-On tool.

7.3 How to Exercise All State Privacy Rights

  1. One-click opt-out of sale/sharing via the "Do Not Sell or Share My Personal Information" permanent link located in our website footer.
  2. Submit a written request via our official support email: avila-dubee-support@aviladubee.com
  3. All verifiable consumer requests will receive a formal response within 45 calendar days as required by U.S. state privacy statutes.

8. Do Not Sell or Share My Personal Information

Under applicable U.S. state privacy laws, cross-site behavioral advertising tracking counts as "sharing" personal information. You may opt out of this data sharing through two permanent methods:
  1. Click the dedicated "Do Not Sell or Share My Personal Information" link published on every page of our website footer; OR
  2. Send a formal opt-out request via our customer support email listed at the bottom of this policy.

9. Global Privacy Control (GPC)

Our website fully recognizes and honors valid Global Privacy Control (GPC) browser opt-out signals in compliance with California, Colorado, Oregon, Texas, and Virginia state privacy regulations. If an active GPC signal is detected from your browser, we will automatically opt you out of all sale and cross-site sharing of your personal data for targeted advertising purposes.

10. Do Not Track Signals

Some web browsers include an optional "Do Not Track (DNT)" signal setting. There is currently no universal legal standard mandating websites to respond to DNT signals, so our Site does not alter data collection based solely on DNT headers. We fully comply with enforceable GPC universal opt-out signals as outlined above.

11. Data Retention

We retain personal information only as long as reasonably necessary for the business purposes listed in this policy, or as required by mandatory legal obligations:
  1. Order, transaction, invoice, and payment records: Retained for a minimum of seven (7) years to satisfy tax, accounting, fraud audit, and customs legal requirements.
  2. Marketing, analytics, and advertising behavioral data: Retained for a maximum of twenty-four (24) months.
  3. Virtual Try-On facial biometric data: No permanent storage; erased instantly after each browsing session.
  4. Customer account profile data: Retained until you submit a formal deletion request, after which we remove all non-mandatory records within 30 business days.

12. International Data Transfers

Your personal information may be transferred to and processed in jurisdictions outside your country of residence, including the United States, Hong Kong, and other countries where our contracted service providers operate.

Where cross-border data transfer legal safeguards are required by GDPR or other regional privacy laws, we implement Standard Contractual Clauses (SCCs) and formal data protection agreements with all third-party processors to protect your personal information.

13. Data Security

We implement reasonable administrative, organizational, technical, and physical security safeguards to protect your personal information against unauthorized access, disclosure, alteration, or accidental destruction.

Our core security measures include:
  • Full-site SSL/TLS encryption for all page loads and checkout transactions
  • Secure cloud hosting infrastructure with regular security patches
  • Role-based access control for internal staff accessing customer data
  • Real-time fraud and suspicious transaction monitoring systems
  • End-to-end encrypted payment processing via PCI DSS compliant providers
No online data transmission or digital storage method can be guaranteed 100% secure against all potential breaches, and we cannot promise absolute data security under all circumstances.

14. Children's Privacy

Our website, sunglasses, and non-prescription plano eyewear products are marketed and intended exclusively for consumers aged 18 years or older.

We do not knowingly collect personal identifiable information from any child under the age of 13. If we become aware that personal data belonging to a minor under 13 has been submitted to our Site without verifiable parental consent, we will take immediate reasonable steps to fully delete all such records from our systems in compliance with COPPA requirements.

15. Changes to This Privacy Policy

We reserve the right to clarify, revise, or update this Privacy Policy periodically to align with new state, federal, and international privacy regulations.

All policy updates will be posted publicly on this page with a revised "Last Updated" date at the top of the document. Your continued use of the AvilaDubee Site after policy changes take effect constitutes your full acceptance of the revised privacy terms.

16. Contact Information

If you have any questions about this Privacy Policy, wish to exercise your state or global privacy rights, or submit data deletion, correction, or opt-out requests, please contact us via the details below:
AvilaDubee

Data Controller: Adele International Trading Co., Limited

Official Support Email: avila-dubee-support@aviladubee.com

Registered Business Address:

Flat 1506, 15/F, Cheung Fung Commercial Building,

21-25 Cheung Sha Wan Road,

Sham Shui Po, Kowloon, Hong Kong