Privacy Policy

PRIVACY POLICY AND PERSONAL DATA PROTECTION

Last Updated: March 2022

Top Cau Industria e Comercio de Chocolates Ltda. (“Top Cau“ or “We“) is committed to your privacy rights. Our current privacy policy (“Privacy Policy“) aims to clarify how we handle personal data collected from the use of the pages we make available on the internet (“Site“) or through our Customer Service System (“SAC“) and which, in both cases, are related to individual users (“Data Subject“ or “You“).

Our intention is to provide transparency to the processing activities we carry out with personal data, always in compliance with applicable legislation. If you require additional clarification, please contact us at: privacidade@topcau.com.br.

Index

1 - What personal data is processed and how is it collected?
2 - What are the purposes of processing your personal data?
3 - Who do we share personal data with?
4 - International transfer of data
5 - Rights regarding your personal data
6 - How do we protect your personal data? 
7 - For how long will we process your personal data?
8 - What are cookies and how are they used?
9 - Third-party websites
10 - Contact
11 - Data controller
12 - Changes to the Privacy Policy

1. What personal data is processed and how is it collected?

Brazilian legislation uses the term “processing“ for all operations performed with personal data. Personal data, in turn, is generally defined as information related to individuals.

We may process the personal data listed below, based on information collected directly, that is, provided by You, or indirectly, and their use, access, and sharing, when necessary, will be done within the limits and purposes described in this Policy.

- Data collected directly:

– Name;
– Phone number;
– Email address;
– Any personal data sent by You through our website, email, or SAC.

- Data collected indirectly:

– Information about the use of our Site, collected by cookies, third-party plugins, or similar technological tools; and
– Information about IP address, location, and time of access to our website, collected by cookies, third-party plugins, or similar technological tools.

We will always observe and respect the applicable legislation when processing your personal data.

2. What are the purposes of processing your personal data?

The processing of personal data provided directly by You is carried out with the intention of:

- Responding to your messages sent through our website, email, or SAC; and
- Sending you our communications and opportunities such as offers, promotions, events, etc.

At any time, You can choose to stop receiving our communications. Simply access the link provided in the message received or send your request to privacidade@topcau.com.br.

The processing of data collected indirectly aims primarily to optimize your browsing experience on our Site, both for performance and usability, as the content made available will be tailored to your needs. Additionally, we use such information to analyze traffic to our Site, so that we can provide relevant content to You.

Finally, we inform you that we extract statistical reports on access and navigation on our Site, solely for the purpose of understanding user profiles. In these cases, the data is anonymized to preserve your privacy.

3. Who do we share personal data with?

We will share your personal data for the sole purpose of enabling the processing purposes mentioned above, always respecting applicable legislation.

Therefore, the data may be shared with hosting providers for our Site, software providers, and other technologies for managing registration, customer service, digital communication, and administrative activities, as well as service providers related to such activities.

In most cases of sharing, we will remain as the controller of your personal data, with the providers, suppliers, or service providers acting as mere processors of such information. This means that the decision regarding the parameters of the processing will be made by Us and not by third parties.

However, it is possible that in certain situations, third parties may take control of your personal data. In such cases, we recommend that You read and agree to the specific privacy and personal data protection policy of the organization in question.

If you have not received such information, please contact us so that we can assist you in obtaining it. We emphasize that, in cases where third parties are controllers of your personal data, they will have the final decision regarding the processing carried out, and Top Cau will have no relationship with the processing or influence over the related procedures.

4. International data transfer

We may share your personal data with hosting providers, software providers, or other technologies, or service providers located outside of Brazil. In such situations, the processing purposes mentioned above remain in place, as well as our role as data controllers.

Whenever possible and necessary, we will also take appropriate measures to ensure that your data remains protected in accordance with applicable legislation.

5. Rights regarding your personal data

- Confirmation of the existence of data processing.
- Access to the data.
- Correction of incomplete, inaccurate, or outdated data.
- Anonymization, blocking, or deletion of unnecessary, excessive, or data processed in violation of the law.
- Portability of data to another service or product provider, upon express request and subject to trade and industrial secrets, if applicable.
- Deletion of personal data processed with your consent, except in cases where legislation requires the retention of such data.
- Information about public and private entities with whom we share data.
- Information about the possibility of not giving consent and about the consequences of refusal; and
- Revocation of consent, in accordance with the law.

The aforementioned rights can be exercised by the data subject by submitting a request to privacidade@topcau.com.br.

6. How do we protect your personal data?

The security of your personal data is very important to us. We have implemented technical, technological, administrative, physical, and managerial measures commonly adopted by the market to preserve your privacy and protect your personal data.

Additionally, our hosting servers, software suppliers, other technologies, and service providers also have security environments and tools focused on the data shared with them.

7. For how long will we process your personal data?

We will process your personal data only for the period authorized by law. The processing will end in the following circumstances:

- Verification that the purpose of the processing has been achieved or that the data is no longer necessary or relevant for the purpose of the processing;
- End of the processing period, if applicable;
- Request from the Data Subject through a specific communication received by us;
- Determination by the competent authorities.

Your personal data will be deleted after the processing ends, except in cases provided for by applicable law.

8. What are cookies and how are they used?

Cookies are small text files sent to your device that collect information about access and usage of web pages. When visiting our Site, we may automatically collect such information through cookies or similar technologies (e.g., third-party plugins).

Although cookies can have different purposes, we use this feature on our Site to enable:

- Functionality: We use cookies that recognize your access to the Site and retrieve your previously selected preferences (e.g., preferred language).

- Content improvement: We use cookies to collect information about how you use our Site, the content that interests you the most, and the links you access. These cookies also collect the following data: browser used, access device, and your IP address. We use this set of information to improve the content offered on our Site, send you materials that are of interest to you, and invite you to relevant events. Additionally, we use the information to extract statistical reports on the access and navigation of our Site in order to understand user profiles. In this case, the data is anonymized to preserve your privacy.

You can change the Site settings to block the use of cookies (indirectly collected data) by consulting your browser's instructions. If you use different devices (smartphone, computer, etc.) to access our Site, you should verify if the browser of each device is adjusted to meet your preferences regarding cookies.

9. Third-party websites

Our Site contains links to pages maintained by third parties on the internet, including social media platforms, which may process your personal data.

Therefore, it is important to clarify that this Privacy Policy is only applicable to our Site and that Top Cau does not act as a controller or processor of personal data obtained from third-party websites. If you access other pages, we recommend that you read the privacy policy that applies to them.

10. Contact

If you have any questions about our Privacy Policy, the data we process, or if you want to exercise your rights related to your personal data, please contact us at: privacidade@topcau.com.br

11. Data Protection Officer

In compliance with current legislation, we have a Data Protection Officer who is responsible for receiving your complaints and communications, providing clarifications, and taking appropriate actions. Below are the contact details:

- Name: Carlos Hashimoto
- Email: privacidade@topcau.com.br

12. Changes to the Privacy Policy

Our Privacy Policy is constantly updated to remain compliant with Brazilian personal data protection legislation. Therefore, this Policy may be adjusted at any time, and it is your responsibility to review it whenever possible on our website. The current version of the Privacy Policy was last updated in March 2022.