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Privacy Policy

Topcon Healthcare Group Privacy Statement

Your privacy and trust are important to us. This Privacy Statement ("Privacy Statement") provides important information about how Topcon Corporation, Topcon Healthcare Solutions, Inc., Topcon Medical Systems Inc., Topcon Europe Medical B.V. and their affiliates (collectively, "Topcon" or "we") process Personal Data that we collect through our websites and online services, as well as our sales and marketing activities (collectively, the "Services").

For the purposes of this Privacy Statement, "Personal Data" refers to any information relating to an identified or identifiable natural person, such as their name, date of birth and home address, email address or telephone number, credit card details and other personal identifiers.

Topcon is committed to complying with the privacy laws that apply to Topcon's operations worldwide (collectively, the "Applicable Laws"). This Privacy Statement has been drafted to meet the requirements of these applicable laws and is intended to inform you of Topcon's procedures for managing and protecting your Personal Data from unauthorized access or disclosure. Applicable laws include, but are not limited to, the European General Data Protection Regulation (“GDPR”), the UK Data Protection Act 2018 (the "UK DPA"), the Australian Federal Privacy Act 1988, the Australian Privacy Principles (APP)"), the California Consumer Privacy Act ("CCPA"), and the Personal Information Protection and Electronic Documents Act ("PIPEDA"), as well as other substantially similar provincial laws applicable in Canada.

Please read this Privacy Statement carefully and contact our Data Protection Officer ([email protected]) if you have any questions about our privacy practices or your Personal Data.

It is important that you check back frequently to see if this Privacy Statement has been updated. An up-to-date version of this Privacy Statement is always available on our website. Upon publishing a new version, a banner and/or pop-up window will temporarily be added to the website in order to notify any website visitors to take a look at the newest version.

This Privacy Statement was last updated in March of 2026.

1. What information does Topcon collect about you?

Topcon collects certain Personal Data from you whenever you interact with us, use our Services, enter your Personal Data on our website, or otherwise provide us with your Personal Data.

This includes data related to customer satisfaction surveys, customer purchasing habits, warranty data and/or other purchasing data. As well as technical data, such as your IP address, MAC address, Internet service provider, computer platform, web browser, geographic location, and any other related technical data. It also includes your company's contact person's first name, last name, address, email address and phone number.

Topcon will only collect Personal Data that is necessary for the purposes identified by Topcon at the time the data is collected or prior to the collection of such data. You are under no obligation to provide Topcon with any Personal Data, but if you do not provide this data, you may not be able to use all features of the Services.

If the Personal Data we receive about you is subject to the APP, you may be entitled to use a pseudonym when interacting with our Services. We also collect Personal Data from third parties, such as our partners, service providers, and publicly available websites, to provide services that we believe may be of interest to you, and to help maintain data accuracy and provide and improve Services.

We do not knowingly collect or use Personal Data from children under the age of 13, including in the future, without verifiable consent from a parent or legal guardian. If a child we know is under the age of 13 sends us Personal Data, we will only use this information to respond directly to the child and seek parental consent or notify the parents.

 

2. Name and contact details of the controller processing Personal Data

 

For our Head Office in Japan

For the Americas

 

For EMEA Region

For Asia Region

3. How does Topcon process your Personal Data?

  1. Topcon collects, obtains, uses, discloses, provides, and retains Personal Data in an appropriate manner.
  2. Topcon makes every effort to ensure that all Personal Data it uses is accurate, accurate, and up to date.
  3. Topcon takes necessary and appropriate measures to manage and protect Personal Data, including to protect Personal Data from unauthorized access and disclosure, loss, leakage, misuse, or damage.
  4. Topcon will comply with its obligations under applicable laws by keeping Personal Data up to date; securely storing and destroying Personal Data; not collecting or storing excessive amounts of data; protecting Personal Data from loss, misuse, unauthorised access and disclosure, and ensuring that appropriate technical measures are in place to protect Personal Data.Topcon retains Personal Data only for as long as strictly necessary to fulfill the agreed-to purposes (on the basis of contractual obligation or Customer consent). When determining data retention periods, Topcon takes into account local laws and contractual obligations, as well as customer expectations and requirements.
  5. Topcon complies with laws, regulations and guidelines, as well as internal regulations regarding Personal Data.
  6. When disclosing the processing of Personal Data to a third party, Topcon will only make use of sub-processors who meet the requirements of Topcon's internal regulations. Topcon manages sub-processors in an appropriate manner, meaning, Topcon enters into Data Sub-processing Agreements with the sub-processors and/or Agreements that cover the sub-processing activities of the sub-processor (such as Distributors that Topcon works with in the regions where Distributor has been appointed as such by Topcon).
  7. Topcon will keep itself informed of changes in applicable laws.

 

4. What is the purpose and legal basis for the processing of Personal Data? 

We collect, use, disclose, transfer and store Personal Data as necessary to provide our Services and for operational and business purposes, as described in this Privacy Statement.

Topcon will ensure that in providing products and Services, it will only process Personal Data that is necessary for the purposes identified and described below. This Personal Data will not be used or disclosed for any purpose other than the purposes for which it was collected, except with the consent of the data subject concerned or as required or permitted under applicable laws.

Topcon processes your Personal Data for the following purposes and on the following legal grounds:

Data being processed

Purpose of processing

Legal basis

Retention Period

First Name, Last Name, Company Name, e-mail, phone number, Country, Professional group, Postcode and City

Sales process and management of contractual relationships related to our services.

Legitimate interest and/or performance of a contract

Personal Data is being retained for as long as the contractual relationship is active, in order to meet the obligations under the Agreement.

First Name, Last Name, Company Name, e-mail, phone number, Country, Professional group, Postcode and City

To perform and use the services as agreed upon with the Customer. Which could be for one or more of below reasons;

design, develop, manufacture, install, support, train and service, provide and share information, e.g. information about the services, contact information regarding warranty, service and sales questions.

Legitimate interest and/or performance of a contract

Personal Data is being retained for as long as the contractual relationship is active, in order to meet the obligations under the Agreement.

First Name, Last Name, Company Name, e-mail, phone number, Country, Professional group, Postcode and City

Providing telecommunications and data processing services, as well as advertising and promotions, exhibitions and other events to promote products and to deliver and suggest customized content such as news, research, reports and business information and to personalize your service experience, as well as to provide and distribute brochures, materials and product samples.

Customer Consent or Topcon's legitimate interest in sending/receiving relevant marketing communications, which is done on the basis of opt-in (i.e. the customer / visitor of the website has the option to opt-in and opt-out for being included in the communications) .

Marketing communications provide an opportunity to refuse to receive direct marketing. If for any reason you were unable to opt out of marketing communications, please contact Topcon by email at [email protected] to unsubscribe. Please note that in some countries, you may be required to opt-in to receive marketing communications.

 

Personal Data is being retained for as long as the (contractual) relationship is active.

IP address, device type, timestamp of visit, browser ID, Cookie ID, referred URL (where the user name came from), Page URL viewed.

Personalizing your experience on our websites; selectively send you information that may be of interest to you; contests and sweepstakes; market research and online surveys; automatic statistical monitoring to determine the use of Topcon websites.

Legitimate interest

Technical personal data is only being retained anonymized to improve functionality of our online services.

First Name, Last Name, Company Name, e-mail, phone number, Country, Professional group, Postcode and City

Conducting surveys on services and analysing the results.

Customer Consent

Personal Data is being retained for as long as the (contractual) relationship is active.

First Name, Last Name, Company Name, e-mail, phone number, Country, Professional group, Postcode and City

Exercising rights and fulfilling obligations imposed and required by laws and regulations.

Compliance with legal obligations

Statutory Period of Claim Rights

First Name, Last Name, Company Name, e-mail, phone number, Country, Professional group, Postcode and City

For the establishment, exercise or defense of legal claims.

Legal right

Statutory Period of Claim Rights

 

When the processing is based on your consent, you have the right to withdraw the consent. However, the withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.

 

5. Cookies

We store "cookies" to provide you with a comprehensive range of functions and to facilitate your use of our websites. Cookies are small files that are stored on your computer using your internet browser. Please be aware that these cookies can identify you as a person to a certain extent, either directly or indirectly. For more information about cookies, please visit the following page https://topconhealthcare.eu/en_EU/cookie-statement.

If you do not want to use cookies, you can prevent cookies from being stored on your computer by changing the settings of your internet browser. Please note that this may limit the functionality and functionality of our offering. 

 

6. Processing of sensitive Personal Data

We will not process any sensitive Personal Data (e.g. health, financial or religious data) within the meaning of Article 9. of the GDPR that we receive from you without your prior written consent, except as otherwise permitted or required by applicable law.

7. Sharing Your Personal Data

Your Personal Data is shared, or is likely to be shared, with:

 

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Affiliates for internal administrative purposes (e.g., business-to-business agreements that require a specific department or group to process Personal Data collected by different Topcon entities). In these cases, Topcon will weigh its legitimate interest in administrative efficiency against your competing interests before sharing your Personal Data. 

 

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Third-party service providers to ensure that they are able to fulfill the services they provide to us, such as software, system and platform support services; direct marketing services; cloud services; advertising; data analytics; and order fulfillment and delivery. Our third-party service providers may only share or use your Personal Data to provide their services to us. We enter into the necessary legal agreements with third-party service providers to protect your Personal Data. Third Parties like Google, META & LinkedIn technical personal data is shared such as IP address, device type, timestamp of visit, browser ID, Cookie ID, referred URL (where the user name came from), Page URL viewed.

 

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Third-party distributors to notify you of important product updates, service issues, and offers, in case you have filled out the form on the website, to receive more information and you chose YES to being contacted about offers. We will only provide your Personal Data to authorized and contracted Topcon distributors and only to the extent that it is appropriate and necessary for distributors to market and service our products. We enter into the necessary legal agreements with our distributors to protect your Personal Data.

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Business Partners - Topcon may share personal information with business partners to enhance your experience with Topcon or for Topcon's marketing purposes in case you have filled out the form on the website, to receive more information and you chose YES to being contacted about offers. Topcon may share non-personalized, aggregated information about sales, customers, site visitors, and related site information with third parties. We enter into the necessary legal agreements with our business partners to protect your Personal Data.

 

 

8. GDPR, UK DPA, and APP Specific Terms – Your rights and Personal Data under the GDPR, UK DPA and APP 

The GDPR, UK DPA and APP give you certain rights over your Personal Data. There are differences between GDPR, UK DPA, and APP; However, generally speaking, each of these laws gives you the rights listed below in relation to your Personal Data.

If you wish to exercise any of the rights below, please contact us by email at [email protected] and let us know that you would like to make a request. 

Right of access

You have the right to request access to the Personal Data we process about you at any time in accordance with Article 15 of the GDPR, the UK DPA and the APP.

Right to rectification of inaccurate data

You have the right to ask us to immediately rectify Personal Data concerning you if this data is incorrect or incomplete.

Right to erasure 

Pursuant to Article 17 of the GDPR and the UK DPA, you have the right to request Topcon to delete all of your Personal Data if (i) the Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, (ii) you withdraw the consent on which the processing is based, (iii)  you object to the processing pursuant to section “Right to object” and there are no overriding legitimate grounds for the processing, (iv) the Personal Data has been unlawfully processed, (v) the Personal Data has to be erased for compliance with a legal obligation in applicable law to which Topcon is subject, or (vi) the Personal Data has been collected in relation to the offer of information society service.

However, Topcon does not have an obligation to erase Personal Data to the extent the processing is necessary  (i) for exercising the right of freedom of expression and information, (ii) to comply with a legal obligation requiring the processing, (iii) for archiving purposes in the public interest, or for scientific or historical research purposes or statistical purposes, or (iv) for the establishment, exercise or defence of legal claims.

Right to object

Pursuant to Article 21 of the GDPR and the UK DPA, you have the right to object, on grounds relating to your particular situation, to the processing of your Personal Data concerning you where the processing is based on either of the following legal basis: (i) the processing is necessary for the performance of a task carried out in the public interest or (ii) the processing is necessary for the purposes of the legitimate interests pursued by Topcon. Topcon Personal Data will then cease all processing of your Personal Data, unless we can demonstrate that: (i) Topcon has a compelling legitimate grounds for processing the data which overrides your interests, rights and freedoms; or (ii) the processing is necessary for the establishment, exercise or defence of a legal claim.

 

Right to restriction of processing 

“Restriction of processing” means the marking of stored Personal Data with the aim of limiting its processing. Pursuant to Article 18 of the GDPR and the UK DPA , you have the right to request Topcon to restrict or suspend the processing of your Personal Data if (i) you want Topcon to verify the accuracy of the data, for a period enabling Topcon to verify the accuracy of the Personal Data, or (ii) you object to the processing of your Personal Data pursuant to section “Right to object” pending the verifications whether Topcon does have an overriding legitimate grounds to process the data, or (iii) the processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of its use instead, or (iv) Topcon no longer needs the Personal Data for the purpose of processing, but the Personal Data is required by you for the establishment, exercise, or defence of legal claims.

In the aforementioned situations, Topcon processes the Personal Data only in the following circumstances: (i) based on your consent, (ii) for the establishment, exercise, or defence of legal claims, (iii) for the protection of another person’s rights, or (iv) for reasons of public interest of the European Union or a Member State.

Right to data portability

Pursuant to Article 20 of the GDPR and the UK DPA, at your request, you have the right to receive the Personal Data concerning you that Topcon processes by automated means based on your consent or based on a contract with you and that you have provided to us, in a structured, commonly used and machine-readable format, and if technically feasible, Topcon shall transmit the Personal Data in the same format directly to another controller.

Right to lodge a complaint

You also have the right to lodge a complaint with the competent supervisory authority in the Member State in which you have your habitual residence or place of work, or where the alleged infringement has occurred, if you believe that Topcon's retention or processing of your Personal Data violates the GDRP or the UK DPA.

You can find a list of all European data protection authorities at the following address: http://ec.europa.eu/justice/article29/structure/data-protection-authorities/index_en.htmhttp://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htmhttp://www.topcon-medical.pl/pl/https://topconhealthcare.com/us/do-not-sell-my-personal-information/.

For the UK, complaints can be lodged with the ICO – https://www.ico.org.uk/make-a-complaint/

 

Specific APP Terms & Conditions

To the extent that the APP applies to Personal Data collected by Topcon about you: 

  • You may contact Topcon at any time if you have any questions or concerns about this Privacy Policy or how your personal information has been processed.
  • You can make a privacy complaint by contacting us by email at [email protected].
  • The Data Protection Officer will first investigate your complaint to determine whether your complaint can be resolved by simple or immediate measures. We usually respond to the complaint within a week.
  • If your complaint requires further review or investigation, we will notify you of receipt of your complaint within one week and will endeavour to investigate your complaint promptly. We may ask you to provide additional information in relation to your complaint and the outcome you are seeking. We then usually gather relevant facts, search for and verify the relevant documents, and discuss with the relevant individuals.
  • In most cases, we will investigate the complaint and provide a response within 30 calendar days of receipt of the complaint. We will let you know if the issue is more complex or if our investigation may take longer.
  • If you are not satisfied with our response to your complaint, or if you believe that Topcon may have violated the APP, the UK DPA or the GDPR, you have the right to lodge a complaint with the relevant data protection authority.
  • You can find the contact details of the Office of the Australian Information Commissioner at the following address: https://www.oaic.gov.au/

 

CCPA Specific Terms (for California residents only)

The CCPA provides California residents with certain rights to request access to and/or request deletion of the Personal Data we collect. If you would like to initiate the CCPA request process, please contact us by email at [email protected] and indicate that you want to make a request. You can also make a request by phone free of charge to 1-866-922-6278.

 

The CCPA does not currently apply to employment-related Personal Data collected from employees, job applicants, contractors, or other similar individuals. In addition, certain requirements of the CCPA do not apply to Personal Data related to transactions/communications.

 

Canadian Special Terms (for Canadian residents only)

Consent to receive emails

With your explicit consent, we may send you information about products or services that may be of interest to you, such as information about current activity, general announcements, upcoming products and services, changes to our products or services, and upcoming events. These messages may be sent in a variety of ways, including by email, text message, or other electronic message, and through the Services. If you choose to register to receive information about products or services that may be of interest to you, we will collect and use your contact information (such as your email address) for this purpose.  

 

You can withdraw your consent to the use of your Personal Data described above by contacting us at [email protected]. You can opt-out of receiving commercial emails to your email address by using the unsubscribe mechanism that you will find in every email we send to you. Even if you opt out of receiving marketing communications, we may still send you certain service messages, such as confirmations or security notices, either by email, through the Services, via SMS, or by other means of communication.

 

If you send us an email or give us feedback through the Services, we will collect your email address and the full content of your email, including attachments, and other information you provide. We may also use and display your full name and email address when you send email notifications to your friends through the Services (e.g., in invitations).

 

Enhancing the protection of Personal Data

Access to your Personal Data will only be granted to employees who have a business need for information or whose duties reasonably require such information.

Right to access and rectification of Personal Data

You have the right to request that we access your Personal Data and have it rectified in accordance with PEPEDA and substantially similar applicable provincial laws. If you want to start the request process, please contact us by email at [email protected] and indicate that you would like to make a request.

We may ask you to provide proof of identity in order to access the existence, use or disclosure of your Personal Data, or any corrections related to it. Such credentials will only be used for the purposes stated above. We will attempt to respond to each of your written requests no later than 30 calendar days after receipt of your request. We will notify you in writing if we are unable to respond to your requests within 30 days. A reasonable administration fee may be charged for the submission of information. The estimated price of the management fee will be announced before the information is disclosed.

Cross-border transfer of Personal Data

Please note that we may transfer information, such as Personal Data, to a jurisdiction that does not have the same data protection laws as Canada, as described in Section 11 below. This information may become available to courts, law enforcement authorities, and national authorities in the jurisdictions where the information is stored. If you do not want your information to be transferred or stored outside of Canada, please do not provide us with any Personal Data. 

9. Cross-border transfer and storage of Personal Data 

Topcon is a global organization, and your Personal Data may and is likely to be stored or processed outside of your home country. We strive to ensure that the information we collect is processed in accordance with the requirements of this Privacy Statement and applicable laws, regardless of the location of the information. Topcon will process Personal Data as described in this Privacy Statement, regardless of its location.

Topcon has networks, databases, servers, systems, support services, and helpdesks in our offices around the world. We work with third parties, such as cloud computing, vendors, and technology support, around the world to serve the needs of our business, workforce, and customers. We strive to ensure that Personal Data is processed, protected and transferred in accordance with applicable laws. In some cases, we may need to disclose or transfer your Personal Data within Topcon or to third parties outside your home country. The territories in which these recipients are located vary from time to time, but may include, but are not limited to, the United States, Japan, the Netherlands, Germany, Belgium, France, Spain, Italy, the United Kingdom, Ireland, Portugal, Australia, Canada, and other countries in which Topcon operates or uses contractors.

We strive to provide an adequate level of data protection when transferring Personal Data from the European Economic Area or Canada to other countries where applicable laws do not provide the same level of protection as your home country. In other words, your rights and safeguards remain with your Personal Data. For example, we use approved contractual clauses, data transfer agreements between multiple parties, intra-group agreements, and other measures designed to ensure that the recipients of your Personal Data protect it. If you would like more information about our data transfer practices, please contact us at [email protected].

10. How long do we keep your Personal Data?

We will de-identify your Personal Data as soon as it is no longer needed for the purposes for which we collected it or for which we have used it in accordance with this Privacy Statement. We generally retain your Personal Data for the period for which it is intended or for the duration of the contractual relationship, as well as for a reasonable period of time in which we keep backups after the data has been deleted. Please find a breakdown of the retention period per purpose of processing above, under 4.

 

12. Security Measures

Topcon takes security seriously and uses appropriate technology and measures to protect Personal Data. Our information security policies and procedures are nearly consistent with generally accepted international standards and are regularly reviewed and updated as necessary to meet our business needs, technological changes, and regulatory requirements.

 

13. Links to Other Websites

Topcon's websites may contain links to other websites. These third-party websites have their own privacy policies and cookies, and we recommend that you familiarize yourself with them. They govern the use of the personal information you submit or personal information collected through cookies when you visit these websites. This Privacy Statement does not apply to third-party websites, and any personal information you provide to third-party websites is at your own risk.