Privacy and Cookies Policy

TOPCON S/A PRIVACY POLICY

TOPCON S/A prioritizes the protection of personal data, maintaining all necessary aspects of security and privacy. We are also committed to transparency in the data processing of our stakeholders. Therefore, this Privacy Policy establishes how we collect, use, and transfer information from clients or other individuals who access or use our website.

By using our services, you understand that we collect and use your personal information as described in this Policy, in accordance with the General Data Protection Law (LGPD, Federal Law 13,709/2018), the consumer provisions of Federal Law 8,078/1990, and other applicable Brazilian legal standards.

TOPCON S/A, hereinafter referred to simply as “A,” as the Data Controller, undertakes to comply with the provisions of this Privacy Policy.

1. What data do we collect about you and for what purpose?

Our website collects and uses some of your personal data to enable service delivery and improve your user experience.

a. Personal data provided by the owner
i. Data provided by users (contact information, professional data, financial or technical information);
ii. Navigation data (e.g., IP address, location, country, browsing time, access time) or data resulting from interactions with our website;
iii. Cookies and Internet tracking systems;
iv. Information about the user’s religious beliefs is collected when filling out their registration.

2. Consent

We process your personal data based on your consent. Consent is the free, informed, and unequivocal manifestation through which you authorize us to process your data. Thus, in accordance with the General Data Protection Law, your data will only be collected, processed, and stored with prior and express consent.

Your consent will be obtained specifically for each purpose described above, demonstrating TOPCON S/A’s commitment to transparency and good faith towards its users/clients, following the relevant legislative regulations.

By using TOPCON S/A services and providing your personal data, you acknowledge and agree to this Privacy Policy, as well as being aware of your rights and how to exercise them.

You may revoke your consent at any time and at no cost. However, it is important to highlight that revoking consent for data processing may make it impossible to perform certain functionalities on the website that depend on this operation. Such consequences will be informed in advance.

3. What are your rights?

TOPCON S/A ensures its users/clients the rights of data subjects provided for in Article 18 of the General Data Protection Law. Thus, you may, at no cost and at any time:

a. Confirm the existence of data processing, in a simplified manner or in a clear and complete format;
b. Access your data, and request a legible copy in print or electronic, secure, and reliable format;
c. Correct your data by requesting edits, corrections, or updates;
d. Limit your data when unnecessary, excessive, or processed unlawfully through anonymization, blocking, or deletion;
e. Request the portability of your data through a registration data report;
f. Delete your data processed based on your consent, except in cases provided by law;
g. Revoke your consent, disallowing the processing of your data;
h. Be informed about the possibility of not providing your consent and the consequences of denial.

4. How can you exercise your rights as a data subject?

To exercise your rights as a data subject, you must contact us through the following channels:

a. Email
b. Phone

To ensure proper identification as the data subject of the request, we may request documents or additional evidence to verify your identity. In such cases, you will be informed in advance.

5. How and for how long will your data be stored?

Your personal data collected will be used and stored for as long as necessary to provide the service or to achieve the purposes listed in this Privacy Policy, considering the rights of data subjects and controllers.

In general, your data will be retained as long as the contractual relationship between you and TOPCON S/A lasts. Once the storage period for personal data has expired, it will be deleted from our databases or anonymized, except in the cases legally provided for in Article 16 of the General Data Protection Law, namely:

a. Compliance with a legal or regulatory obligation by the controller;
b. Study by a research body, whenever possible, ensuring the anonymization of personal data;
c. Transfer to third parties, provided the data processing requirements set forth in this Law are respected; or
d. Exclusive use by the controller, provided the data is anonymized and access by third parties is prohibited.

In other words, personal information about you that is essential for compliance with legal, judicial, and administrative requirements and/or for exercising the right of defense in judicial and administrative proceedings will be retained, despite the deletion of other data.

The storage of collected data reflects our commitment to ensuring the security and privacy of your data. We employ technical and protective solutions to ensure the confidentiality, integrity, and inviolability of your data. Additionally, we implement security measures appropriate to the risks and maintain controlled access to stored information.

6. What do we do to keep your data secure?

We use physical, electronic, and managerial tools designed to protect your privacy. These tools are applied considering the nature of the personal data collected, the context and purpose of the processing, and the risks that potential breaches pose to the rights and freedoms of the data subjects. Among the measures we adopt, we highlight the following:

a. Only authorized individuals have access to your personal data.
b. Access to your personal data is granted only after a confidentiality commitment.
c. Your personal data is stored in a secure and reliable environment.

TOPCON S/A is committed to adopting the best practices to prevent security incidents. However, it is important to highlight that no virtual environment is entirely secure and risk-free. Despite all our security protocols, issues beyond our control may occur, such as cyberattacks by hackers or incidents resulting from negligence or imprudence on the part of the user/client.

In the event of security incidents that may pose significant risks or harm to you or any of our users/clients, we will notify the affected parties and the National Data Protection Authority about the occurrence, in accordance with the provisions of the General Data Protection Law.

7. With whom can your data be shared?

TOPCON S/A, with the aim of protecting your privacy, will not share your personal data with unauthorized third parties.

Your data may be shared with future business partners, and we will inform you which data will be shared and with whom.

These partners will only receive your data to the extent necessary to provide the contracted services, and our contracts comply with Brazilian data protection laws.

However, our partners have their own Privacy Policies, which may differ from ours. We recommend reading these documents.

Additionally, there are other cases where your data may be shared:

a. Legal requirements, requests, or court orders from judicial, administrative, or government authorities.
b. In cases of corporate movements such as mergers, acquisitions, or incorporations.
c. For the protection of TOPCON S/A’s rights in any type of dispute, including legal cases.