Washington Consumer Health Data Privacy Policy

Washington Consumer Health Data Privacy Policy

Effective Date: May 29, 2026
This Washington Consumer Health Data Privacy Policy (“Washington Policy”) describes how we Process the Consumer Health Data of Washington Consumers that interact with AvilaDubee (“AvilaDubee,” “we,” “us,” or “our”), and any of our affiliates. “Washington Consumers” are Washington residents and individuals whose Consumer Health Data is Collected in Washington pursuant to the Washington My Health My Data Act (“Washington Act”). This Washington Policy applies to the processing of Consumer Health Data obtained through our websites that link to this Washington Policy, including aviladubee.com (each, a “Site”) and our mobile applications (each, an “App”) (collectively, the “Services”).
For purposes of this Washington Policy, “Consumer Health Data” means Personal Information that is linked or reasonably linkable to a Washington Consumer and that identifies the Washington Consumer’s past, present, or future physical or mental health status. Capitalized terms that are not otherwise defined in this Washington Policy shall be defined as they are in the Washington Act.
In the event of a conflict between any other AvilaDubee policy, statement, or notice and this Washington Policy, this Washington Policy will prevail as to Consumer Health Data Processed under the Washington Act.
From time to time, we may clarify, revise, or update this Washington Policy, which may include making changes to the way we Process Consumer Health Data. If we make any changes to this Washington Policy, we will revise the date at the top of the Washington Policy. Changes to this Washington Policy will become effective once they are posted.

1. Consumer Health Data Collection, Use, and Purpose

We use cookies, software development kits, and similar technologies to automatically collect your IP address, unique identifier, and internet or other electronic network activity information when you access our Services. This information may be considered consumer health data under the Washington Act when you use certain features and functionalities, including when you use our Virtual Try-On feature for sunglass and non-prescription frame preview, access blog articles that include UV eye protection and wellness content, and review our general lens UV protection guidance for casual eye care. We use this information to support the functionality of our Services, help you navigate the Services more efficiently, and provide access to these eye wellness educational resources.
All facial biometric data captured via Virtual Try-On is only processed temporarily during your active browsing session and is never permanently stored on our servers or shared with third parties, as further detailed in our main site Privacy Policy.

2. Consumer Health Data Sharing and Disclosure

We Share the categories of Consumer Health Data described above to the extent necessary to provide Services requested by the Washington Consumer, with the Washington Consumer’s Consent, or as legally required, including to:
  • Federal or Washington state regulators, where required or permitted by applicable law.
  • Our Affiliates to carry out our operations and provide Services to Washington Consumers. Our Affiliates include Adele International Trading Co., Limited.
We may also disclose Consumer Health Data to:
  • Our Processors to provide Services in a manner consistent with the purpose for which the Consumer Health Data was Collected and disclosed. All processors execute strict data confidentiality agreements restricting secondary reuse of health data.
  • Parties with whom the Washington Consumer has a direct relationship for the purpose of providing Services requested by the Washington Consumer, in circumstances where we maintain control and ownership of the data and the party only uses the Consumer Health Data at our direction for the purpose for which the Consumer Health Data was Collected or Consented to.
  • External parties as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the party may assume control of all or part of our assets.
We will not Sell Consumer Health Data without first obtaining valid written authorization from the applicable Washington Consumer. At this time, AvilaDubee does not sell any consumer health data collected from Washington visitors.

3. Consumer Health Data Rights

Washington Consumers have the right to submit certain requests relating to Consumer Health Data, as described below.
  • Right to Confirm: Washington Consumers have the right to confirm whether we are Collecting, Sharing, or Selling their Consumer Health Data. At this time, we do not Sell Consumer Health Data.
  • Right to Access: Washington Consumers have the right to access their Consumer Health Data stored in our systems.
  • Right to Deletion: Washington Consumers have the right to request that their Consumer Health Data be fully deleted.
  • Right to Withdraw Consent: Washington Consumers have the right to withdraw Consent from our Collection and Sharing of their Consumer Health Data at any time.
  • Right to Obtain Sharing Information: Washington Consumers have the right to obtain a list of all Third Parties and Affiliates with whom we have Shared their Consumer Health Data and an active email address or other online mechanism to contact those Third Parties.

Exercising Your Rights

To exercise your privacy rights under the Washington My Health My Data Act, please email us at avila-dubee-support@aviladubee.com.

Identity Verification

In order to exercise these rights, you will need to verify your identity to protect your security and Consumer Health Data, which may include providing order information, registered email address, or other account matching details.

Appeal Process

We may deny your privacy rights request in certain limited circumstances permitted under the Washington Act. If your privacy rights request has been denied by us and you believe we denied it in error, you may submit a formal appeal for reconsideration of your request by emailing us at avila-dubee-support@aviladubee.com. In the event we deny your appeal, we will provide a written explanation of the decision, and instructions on how to contact the Washington State Attorney General for further independent review.

Non-Discrimination Guarantee

We will not discriminate against you, charge higher prices, or restrict product access because of your exercise of any of your privacy rights under this Policy or the Washington My Health My Data Act.

4. Contact Us

If you have any questions about this Washington Policy or our privacy practices related to Consumer Health Data, please contact us at avila-dubee-support@aviladubee.com.
Operated by: Adele International Trading Co., Limited

Registered Address: Flat 1506, 15/F, Cheung Fung Commercial Building, 21-25 Cheung Sha Wan Road, Sham Shui Po, Kowloon, Hong Kong