1. GENERAL PROVISIONS 

1.1. This Privacy Policy (this “Policy”) applies to all personal data collected by Yukon Advanced Optics Worldwide, UAB, company registered address is Ateities 21C, Vilnius, Lithuania, legal entity code 300149641 (also referred to as “we”, “us”, or “our”, “Company”), through its digital environment, including websites (the “Website”), mobile applications, and other related services (collectively, the “Platform”), as well as through other interactions with the Company. These include the purchase of products or use of services, participation in Company-organized events, direct communications with the Company (whether in person or via the Platform), and activities related to recruitment and employment. 

1.2.This Policy outlines how the Company processes Personal Data from any users of the Website or mobile app, clients, partners other persons (hereinafter collectively – “you” and/or the “Client”) both through our digital channels (including websites and mobile applications) and through other interactions, such as in connection with the sale of our products. 

2. THE PURPOSE OF THIS POLICY 

2.1. This Policy supplements the other notices and is not intended to override them. Terms used within it shall have the meaning(s) given in the Regulation (EU) 2016/679 (General Data Protection Regulation (GDPR)), as applicable. This Policy describes how the Company processes Personal Data that we obtain from you when using the Platform and any services provided through the Platform, as well as through other means. This includes processing Personal Data of any person who orders, purchases, or uses our goods; contacts us; whom we contact; or who has expressed an intention to use, or in any way uses, the Company’s services, intends to purchase or purchases the Company’s goods, and/or is otherwise related to or interested in the services or goods provided by the Company. It also explains how we use and disclose that information. 

2.2. This Policy is designed to help you understand what kind of Personal Data we collect in connection with our goods and services and how we will process and use this information. We understand this is a big responsibility and work hard to protect your information and put you in control.  

2.3.This Policy also helps you understand your legal rights to your Personal Data and explains our lawful basis for processing Personal Data and who to contact should you have a query on the collection and use of your Personal Data. 

3. WHAT IS PERSONAL DATA? 

3.1. Personal Data is information relating to an identified or identifiable natural person. Examples include an individual’s name, age, date of birth, gender, contact details, national identity number, passport details, etc. 

4. THE PERSONAL DATA WE COLLECT ABOUT YOU  

4.1. We collect and process Personal Data about you directly from you when you contact us, submit information to us for contract conclusion, use the Platform, or submit information automatically through your use of the Platform. We may also collect or receive Personal Data from third party service providers, state institutions or other persons that may have a legal ground to provide the Personal Data to us. 

Please note that if you are acting as an authorized individual on behalf of a Client and are providing Personal Data for such Client, you are responsible for ensuring that you have all required permissions and consents to provide such Personal Data to us for use in connection with the Platform and that our use of such Personal Data you provide to the Platform does not violate any applicable law, rule, regulation or order. 
Marketing and Communications Preference Data includes your consent and preferences in receiving direct marketing communications from us and our third-party partners, as well as your communication preferences (such as preferred contact methods). It also includes the processing of data related to newsletter and advertising recipients, such as your name, email address, language preference, and the date and time of subscription or unsubscription. You may update your preferences or withdraw your consent at any time by following the opt-out instructions provided in our communications or by contacting us directly. 
Identification Information: We may collect the following information when you conclude a contract or in performance of a contract, or for identification purposes: full name, date of birth, national identification number (if required by law), postal address, email address, and phone number, information about general managers, ultimate beneficial owners, etc. We also collect any other information relating to you which you have provided to us in any forms that you may have submitted to us, or in other forms of interaction with you. 
Financial Information, such as credit or debit card details (including card number, expiration date, and CVC), bank account number (for bank transfers or refunds), tax identification number (if applicable), and other relevant billing information. 
Transaction Information: may include transaction information as you purchase our goods, including details of the goods you purchase, order dates and amounts, shipping and delivery records, order history, and return or cancellation activity; 
Candidates, Employees and Screening Information: includes Personal Data of the candidates and employees, such as CV, employment history, education background, professional qualifications, and income levels. Where permitted or required by law, we may also process data relating to imposition of national / international sanctions, criminal convictions and offences, including information concerning fraud, money laundering, or other relevant background checks necessary for assessing suitability for employment or continued engagement with the Company. 
Support or Feedback Information: We may collect information you provide during any support or feedback communications via email, telephone, or when you contact us through contact forms on the Platform. This includes messages, questions, or other content you submit to us. We use this information to respond to your inquiries, provide support, and improve our services and the user experience on the Platform. This also includes data received through messages or inquiries sent via our social media accounts (e.g., Facebook, LinkedIn, or other social networks). 
Usage Information: We collect information about your use of the Platform, such as your IP (Internet Protocol) address, browser type, pages viewed, time spent on pages, traffic to and from our websites, referral sources, and other browsing behavior. We may also collect data using cookies and similar technologies that track interaction with our Platform. This may include general user attributes, such as age, hobbies, number of devices owned, favorite hunting locations, and similar preferences. We may also access your device’s camera if you grant permission to allow photo uploading, scanning, or other user-initiated actions within the Platform. We may also access your device’s media storage or gallery, allowing you to save media files created in the Platform to your device, or to display and use media files stored on your device within the Platform. This Personal Data is collected automatically. 
Network and Connection Information: We collect device-specific data, including device attributes (such as device ID, operating system, hardware and software versions, battery level, signal strength, and available memory), third-party application identifiers (such as Google token, Facebook token, push token, and Apple ID), and device statistics (including SKU number, hardware version, firmware version, and serial number). We may also collect information about connected devices, including model, type, time spent using the device, actions that the user does with the device, and ballistics (post-event records, including the occurrence of a shot, session logs, device usage statistics, and related data (time and date of the event, device identifiers, and, if enabled, approximate location at the time of detection)) or settings (changing settings, actions with the device (measuring distance, recording media, ballistic calculations, etc.), actions with the app and collecting software errors). We may collect Bluetooth signals and information about nearby Wi-Fi hotspots, beacons, and cell towers. Additionally, we may receive data from your device settings.

If you have provided permission through your mobile device to allow us to collect location information through a mobile application, we may obtain your physical location information in terms of latitude and longitude from technologies like GPS, Wi-Fi, or cell tower proximity. You can withdraw your permission for us to acquire such physical location information from your mobile device through your mobile device settings, although we do not control this process. If you have questions about how to disable your mobile device’s location services, we recommend you contact your mobile device service provider or the mobile device manufacturer. This Personal Data is collected automatically. 
Session Replay and Diagnostics Data. With your consent, we may use session replay technologies that record your interaction with the Platform, including mouse movements, clicks, scrolling, navigation, device information and technical logs. To reduce risk, the contents of password, payment and other sensitive fields are masked or excluded by configuration. This data helps us diagnose issues, assure quality and improve the user experience. 
Participation, Events and Engagement Information: We may collect Personal Data when you participate in contests, prize draws, or other promotional campaigns organized by the Company. This includes information required to enter such activities, your consent to participate, and details about any prizes awarded. We may also process Personal Data of individuals invited to attend company-organized events or celebrations (e.g., photos, videos, or similar media content captured during such events), which may be used for internal purposes or promotional materials in accordance with applicable laws and your consent where required. 
We may combine this Personal Data with other information that we have collected about you. 

5. WHY DO WE NEED YOUR PERSONAL DATA 

5.1. Your Personal Data is required to enable us to provide you with our goods or services, to verify your identity, to respond to any requests from you about goods or services we provide and to process complaints. 

6. HOW IS YOUR PERSONAL DATA COLLECTED 

6.1. We use different methods to collect Personal Data from and about you including through:  

a) Direct interactions  

You may provide us with your Personal Data by filling in forms or by corresponding with us via our mobile apps, Website or by post, phone, email or otherwise. This includes Personal Data you provide when you:  
          1. apply to conclude a contract; 
2. apply to purchase our products;  

3. apply to use our services (including activities in our website and other applications); 

4. register an account in mobile app; 

5. apply for a job position of the Company or related companies; 

6. contact us, submit information to us;  

7. give us some feedback or lodge a query.  

b) Third parties or publicly available sources  

6.2. We may receive Personal Data about you from various third parties and public sources as set out below:  
           1. Our partner who shares your Personal Data with us in order to perform a contract; 

2. analytics providers such as Google Firebase, Amplitude or Clever Tap based outside the EU, which may also offer session replay functionality, based inside OR outside the EU.;  

3. advertising networks such as Google based inside OR outside the EU; and  

4. search information providers Google based inside OR outside the EU;  

5. social networks such as X, Facebook, LinkedIn based inside OR outside the EU.  

7. OUR LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA 

7.1. We process your Personal Data using one of the following legal basis: 

a) Performance of a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering such a contract; 

b) Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us; 

c)Legal requirement means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to; 

d) Consent means processing your Personal Data using your written consent. 
Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your Personal Data. 

8. HOW WE USE YOUR PERSONAL DATA 

8.1. We will only use your Personal Data when the law allows us to. Most commonly, we will only use or disclose your Personal Data to the third parties for the following purposes: 
  • To provide our Platform to you, to facilitate support and feedback and to communicate with you about your use of our Platform, to respond to your inquiries, to fulfill your orders, and for other customer service purposes; 
  • To facilitate the purchase of products / services, including to fulfill and deliver your orders, provide invoices or receipts, and ensure proper handling of returns, warranties; 
  • To verify your identity, in order to ensure accurate order processing, delivery of products, and access to services provided by the Company. 
  • To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using our Platform; 
  • To better understand how Clients access and use the Platform, both on an aggregated and individualized basis, in order to improve our Platform and respond to Client desires and preferences, and for other research and analytical purposes; 
  • To manage our relationship with you, including notifying you about changes to our Policy or other policies, ask you to leave a review or take a survey; 
  • To provide and personalize features within the app, as well as to analyze its performance and improve your overall user experience 
  • To enable you to partake in a prize draw, competition or complete a survey; 
  • To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); 
  • To perform accounting and financial reporting activities, including invoicing, tax compliance, and maintaining proper business records in accordance with applicable legal requirements 
  • To evaluate and select candidates for employment positions; 
  • For direct marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, to conduct sweepstakes and contests, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our Platform on third-party websites. 

8.2. In addition, we or our partners may use or disclose your Personal Data to: 
  • comply with any legal obligation required under legal requirement (e. g. to state authorities); 
  • enforce any part of our agreements concluded between you and us or to investigate potential breaches; or 
  • protect our rights or our property, or those of our other Client. 

8.3. With your consent, we may use automated tools and algorithms, including machine learning, to analyse your usage patterns and feedback data. This helps us personalize your experience, improve the accuracy of device features, enhance support services, detect technical issues, and improve the overall performance and security of the Platform. You may withdraw your consent at any time by adjusting your preferences in the Account Settings. 

8.4. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions. 

9. HOW WE SHARE YOUR PERSONAL DATA 
Affiliates. We may disclose the Personal Data we collect from you to our affiliates or subsidiaries solely for the purpose of providing the Platform to you or perform a contract concluded with you; however, if we do so, their use and disclosure of your personally identifiable information will be maintained by such affiliates and subsidiaries in accordance with this Policy.  
Service Providers. We may disclose the information we collect from you to third-party vendors, service providers, contractors or agents who perform functions on our behalf (e.g. auditors, accountants, lawyers, IT service providers, marketing, media agencies), provided such third parties have agreed to only use such information to provide services to us. 
Business Transfers. If we are in negotiations with, or are acquired by or merged with another company or entity, if substantially all of our assets are transferred to another company or entity, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company or entity. 
In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.  
To Protect Us and Others. We also may disclose the information we collect from you if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our agreements or this Policy, or as evidence in litigation in which we are involved.  
Aggregate and De-Identified Data. We may collect, process, analyse and share aggregate or de-identified information about Clients with third parties and publicly for product development, marketing, advertising, research or similar purposes. 

10. PERSONAL DATA TRANSFER 

10.1. We may transfer your Personal Data outside of the EEA. Such transfers are carried out in compliance with the GDPR, for instance appropriate Standard Contractual Clauses and/or Adequacy decisions are set in place to ensure that your Personal Data is treated securely and in accordance with this Policy. 

11. RETAINING YOUR PERSONAL DATA 

11.1. We retain your Personal Data as long as it is required in order to fulfill the relevant purposes described in this Policy, as well as are required by applicable law. 

11.2.We will cease to retain your Personal Data, or remove the means by which the Personal Data can be associated with particular individuals, as soon as: 
(a) the purpose for which that Personal Data was collected is no longer being served by its retention; and 
(b) retention is no longer required by applicable laws, accounting, or business purposes. 

11.3. Please note that certain laws may require us to retain records of your Personal Data for a certain period of time even after you cease relationship with us. 

11.4. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements and recommendations. 

11.5. The retaining of Personal Data is necessary for business administration and legal purposes. Sometimes we may need to retain your data for longer, for example if we are representing you or defending ourselves in a legal dispute or as required by law or where evidence exists that a future complaint may occur. 

12. YOUR RIGHTS REGARDING YOUR PERSONAL DATA 

12.1. Data Subjects are provided with legal rights governing the use of their Personal Data.  

12.2. Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data: 
  • Right of access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it. 
  • Right of rectification of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 
  • Right to erase your Personal Data (also known as “right to be forgotten”). This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
  • Right to object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 
  • Right to restrict of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
  • Right of data portability. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 
  • Right to withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent; 
  • Right not to be the subject only to automated processing, including profiling. You have a right to demand that processing of your Personal Data would be reviewed by a real person and to object to the decision made by automated means. 
  • Right to submit an appeal on the actions or inactions of us, related to the implementation of your rights to the Data Protection authority (State Data Protection Inspectorate). 

12.3. Please note that notwithstanding the foregoing, there may be circumstances in which we are unable to accommodate a request to edit, update, access, or delete an account profile or Personal Data. This includes but is not limited to: 
  • any basis where such request can be denied under applicable law; 
  • where we need to retain the information to comply with international or national laws or for accounting or tax purposes; 
  • where we need to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by state, or local authorities; 
  • where we need to cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate laws; 
  • where we need to retain information to exercise or defend legal claims; 
  • where the information contains legal privilege or proprietary information of another party; or where complying with the request would compromise others’ privacy or other legitimate rights. 

12.4. If we determine that we cannot respond to any request in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before responding to any request under this provision, including complying with any applicable legal requirement for verifying your identity. 

12.5. We will respond to your requests without undue delay and in any event within one month of receipt of the request. However, period may be extended up to two months as per circumstances designated by GDPR. 

12.6. You can also complain to the State Data Protection Inspectorate if you are unhappy with how we have used your data. We would, however, appreciate the chance to deal with your concerns before you approach the State Data Protection Inspectorate so, please contact us in the first instance. 

The State Data Protection Inspectorate’s address: 

L. Sapiegos str. 17, LT-10312 Vilnius, Lithuania. 

Email: [email protected]. 

Website: https://vdai.lrv.lt/en/ 

13. PROTECTING YOUR PERSONAL DATA  

13.1. We will take all appropriate technical, physical and organizational steps to protect the confidentiality, integrity, availability and authenticity of your Personal Data, including when sharing your Personal Data to third parties. We will implement appropriate technical and organizational security measures against unauthorized or unlawful processing, access, disclosure, copying, modification, storage, reproduction, display or distribution of Personal Data, and against accidental or unlawful loss destruction, alteration, disclosure or damage of Personal Data. 

13.2. We build security into our services to protect your information. All our products are built with strong security features that continuously protect your Personal Data. The insights we gain from maintaining our services help us detect and automatically block security threats from ever reaching you. And if we do detect something risky that we think you should know about, we’ll notify you and help guide you through steps to stay better protected. 

13.3. We regularly review this Policy and make sure that we process your information in ways that comply with it. 

13.4. The Client is responsible for providing the confidentiality of passwords, Client names other information about access to Personal account and Platform. 

13.5. The Client is responsible for performed actions and operations with the usage of registration information. In the case of undesirable disclosure of information about personal login or password, the Client may change the password independently at the site of the Company. If personal information is disclosed (login or password) to the third parties due the fault of the Client, the Company is not responsible for information security and safety. Company should be immediately notified if you become aware of unauthorized use or access of your account or Client credentials. 

13.6. The Company guarantees the confidentiality of Clients and their private information and assumes all possible measures for its providing, including observation of standards of security during transmission of the confidential information and usage of present-day keeping technologies. 

14. COOKIES 

14.1. For better communication via the Internet, the Company sometimes uses small text files (cookies) remembered by your browser according to its settings so that you can navigate through our Website more easily. We also use this technique where appropriate to keep track of page views and personalise your communication with the Company. We implement some of these cookies through our server technology on your storage device. The use of cookies is now standard procedure for most Websites; however, if you are uncomfortable with cookies, change your browser settings to opt out of receiving cookies. This, however, may limit your ability to interact with the Company sites. 

14.2. Full list of Cookies used are listed in Annex 1.1. of this policy. 

15. THIRD-PARTY LINKS 

15.1. Our Platform may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites. 

16. COMPLAINTS 

16.1. If you are dissatisfied with any aspect on how we process your Personal Data please contact our us by emailing [email protected] or by post: Lithuania, Ateities str. 21C, LT-06326 Vilnius, UAB “Yukon Advanced Optics Worldwide” 

17. HOW TO CONTACT US  

17.1. If you have any questions regarding this Policy and its content, the use of your data and your data subject rights, please contact us at Lithuania, Ateities str. 21C, LT-06326 Vilnius, UAB Yukon Advanced Optics Worldwide address or by [email protected] 

18. CHANGES TO THIS POLICY 

18.1. This Policy is current as of the Last Update Date set forth below. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on the Platform. If we make any changes to this Policy that materially affect our practices with regard to the Personal Data we have previously collected from you, we will endeavour to provide you with notice in advance of such change by highlighting the change on our Platform or providing a push notification through the mobile apps or Website (you should make sure mobile apps or Website settings allow for such push notifications) or sending an email (for this reason you should make sure to update your account information promptly if it changes). 

LAST UPDATE DATE: 10 October, 2025