IMPLEMENTATION FORM
PRIVACY POLICYHORIBA INSTRUMENTS BRASIL LTDA.
TCA/HORIBA SISTEMAS DE TESTES AUTOMOTIVOS LTDA.
1. GOAL•2.

To demonstrate the commitment and the procedures adopted by HORIBA INSTRUMENTS
BRASIL LTDA., aiming at the protection of Personal Data, including on the online platform, by theCompany, which will also be applicable to the Company member of Horiba Group TCA/HORIBASISTEMAS DE TESTES AUTOMOTIVOS LTDA. ("TCA/HORIBA"), once the electronic site isused by both, being TCA/HORIBA responsible for the internal procedures related to the documentapproval collection.
TARGET PUBLIC•3.

Holders of personal data related to the Companies' activities.
APPROVAL•4.

Members of the Personal Data Protection Executive Committees.
REFERENCES•

General Law of Personal Data Protection - LGPD (Federal Law N° 13,709/2018) and•Good Practices Guide to the General Law of Personal Data Protection (LGPD) made available by theCentral Committee of Data Governance of the Federal Government.

5.

TRAINING

☐ Yes
■ No
6.

PLACE OF AVAILABILITY•

Directory of each Company and in the online portal specified below:
https://www.horiba.com/bra/7.

ACCESS•

Full to all users related to HORIBA and TCA/HORIBA activities.
Jundiaí - SP, July 11th, 2022.

1

PRIVACY POLICYHORIBA INSTRUMENTS BRASIL LTDA.
Rua Presbítero Plínio Alves de Souza, nº 645
Lote Multivias - Jardim Ermida II
Jundiaí – SP
CEP 13.212-181

CNPJ/ME nº 01.759.236/0001-79

TCA/HORIBA SISTEMAS DE TESTES AUTOMOTIVOS LTDA.
Avenida Luigi Papaiz, nº 239, Setor Módulo 5, Galpão F, Campanário
Diadema – SP
CEP 09.931-610

CNPJ/ME nº 05.018.399/0001-51

Privacy Policy ("Policy") is the document of HORIBA and TCA/HORIBA that formalizes the observanceand commitment of the Companies with the adoption of measures for protection and privacy of personal
data treated within the scope of their activities, including online mode, having as basis the Brazilian
legislation in force, especially Federal Law N° 13,709/2018 (General Law of Protection of Personal Data LGPD).

Disclaimer
The information contained in this document may be privileged and confidential and protected fromdisclosure. If the reader of this document is not the intended recipient, or an employee agent responsible fordelivering this document to the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication is strictly prohibited.

2SUMMARY
1. GLOSSARY.............................................................................................................................................................42. IDENTIFICATION OS THE DATA COLLECTED BY HORIBA AND TCA/HORIBA ......................... 4
3. SHARING LINES..................................................................................................................................................54. SITE NAVIGATION INFORMATION ............................................................................................................ 6
5. EMBEDDED CONTENT ..................................................................................................................................... 66. USER RIGHTS....................................................................................................................................................... 67. DATA STORAGE AND LOGGING...................................................................................................................78. PROTECTION WAYS............................................................................................................................................79. FURTHER INFORMATION.................................................................................................................................810. CONTACT..............................................................................................................................................................83

1.

GLOSSARY▪

Personal Data: All information related to an identified or identifiable natural person, such as, but notlimited to, a CPF/RG number, telephone number, license plate number, name, etc.

▪

Holder of personal data: Natural person to whom the personal data processed by HORIBA orTCA/HORIBA refers to.

▪

Treatment: Any operation performed with personal data, such as those related to the collection,production, reception, classification, use, access, reproduction, transmission, distribution, processing,archiving, storage, deletion, evaluation or information control, modification, communication, transfer,dissemination, or extraction.

▪

Foreman: Person chosen to act as a communication channel between the data holder, HORIBA orTCA/HORIBA and the National Data Protection Authority (ANPD).

▪

Anonymization: Use of reasonable and available technical means at the time of processing personaldata, whereby a data loses the possibility of association, directly or indirectly, with an individual,
making it impossible for the data to identify a natural person.

▪

Cookies: Storage files of user browsing preferences saved by the websites on the holders' computers.

▪

IP Address: Code assigned to a device that allows its identification, defined according to internationalparameters (Internet Protocol).

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LGPD: Federal Law nº 13.709/2018 (General Law of Personal Data Protection) regulating theprocessing of personal data.

▪

Website: Portal https://www.horiba.com/bra/ and its subdomains.

2.

IDENTIFICATION OF THE DATA COLLECTED BY HORIBA OR TCA/HORIBA

2.1. Personal data may be collected at the moment of the holder's interaction with the HORIBA andTCA/HORIBA website, as shown in the following table:
PurposeRequest for information

Data▪ Name▪ Surname▪ Company or Institution▪ ZIP Code▪ City▪ Country▪ Estate▪ E-mail▪ Telephone▪ Message▪ Surname and Name
▪ E-mail▪ Telephone▪ Company▪ Message▪ User’s name or E-mail▪ Password▪ E-mail, telephone, or Skype

Contact us

Technical Support
MEDigital – Resources for partners
Contact form

▪ Name▪ Surname▪ E-mail▪ Telephone4▪ Company or Institution▪ City▪ ZIP Code▪ Country▪ Estate▪ Message

2.2. The holder is responsible for the accuracy and updating of his personal data provided to HORIBA orTCA/HORIBA. HORIBA and TCA/HORIBA are not obliged to process data if they find that the processing
may be contrary to the law or if their website is being used for illegal purposes.
2.3. The personal data considered by HORIBA or by TCA/HORIBA are property and responsibility of theCompany that considered the personal data, whereas the use, storage, eventual sharing, and elimination are
made in accordance with the Brazilian law of protection of personal data, never being monetized thepersonal data considered.
2.4.

To conduct its business activity, HORIBA and TCA/HORIBA may also process:

▪
▪
▪
▪
▪
▪
▪

Personal data such as gender and age;
Job title and position within your own company or department;
Career history;
Work details;
Data derived from IT systems, such as IP addresses and location information;
Information required for contract execution;
Sensitive data.

2.5. HORIBA and TCA/HORIBA may obtain, use, and process data relating to various individuals, suchas employees, business partners, claimants, relatives and associates of the individual concerned, advisors,consultants and other current, former and prospective professionals and team members, on condition thatthey have a specific purpose and that the processing is in accordance with Brazilian law.
3.

WAYS OF SHARING PERSONAL DATA

3.1. Personal data collected by HORIBA or TCA/HORIBA and recorded activities (logs) may be shared
with:i)emergency services, educational and training institutions, examining bodies, and research and analysis
organizations;ii)

judicial, administrative, and governmental authorities when there is a legal determination or request;iii)

data processors working on behalf of HORIBA or TCA/HORIBA, as well as the headquartersorganization and its subsidiaries/affiliates;iv)

suppliers and partner and potential companies, to enable their activity and the Company'sperformance;v)

employees and consultants, whether internal or external, current, former or future;vi)

automatically, in the occurrence of corporate movements, such as mergers, acquisitions, orincorporations.

3.2. HORIBA and TCA/HORIBA declare that the treatment of personal data performed in their businessactivities will always have a purpose and will observe the justifying legal bases indicated in the applicable5

legislation.
3.3. As part of an organization with global reach, there may be sharing of personal data within theHORIBA Group abroad, where countries have an adequate level of data protection. In any case, all transfers
are subject to the contractual framework regarding the transfer of data within the HORIBA group, which
includes standard contractual clauses published by the European Union.
4.

WEBSITE NAVIGATION INFORMATION

4.1. The website, like most websites, collects information that is not capable of identifying the website
visitor, such as, but not limited to, browser type, language preference, date, and time of the visitor's request,
in order to understand the need of each user.
4.2. HORIBA and TCA/HORIBA inform that they use tracking tools on their website, such as Google
Analytics to analyze their website and improve functionality according to the needs of the user. Theseplatforms set the cookie to store anonymous information about how the visitor has arrived at the website,what has he visited, how long he has stayed on the site and what his interests are. There is no identificationof the visitor. The storage and treatment may occur outside Brazil by HORIBA subsidiaries. Other
information related to cookies can be found in the site's Cookies Policy.
4.3. When browsing HORIBA/TCA HORIBA social networks or blog, cookies may be stored in yourbrowser. The privacy of this information derives from the preferences of the social networks and knowledgeof the privacy policies of these portals is the responsibility of the user, as they are not part of the domain or
responsibility of HORIBA/TCA/HORIBA.
5.

CONTENT EMBEDDED ON THE WEBSITE

5.1. Content of the HORIBA/TCA/HORIBA website may contain embedded media, such as, for example,
videos, images, articles, among others. This content behaves identically to that observed in the user's visit toits origin site, and may collect data, use cookies, incorporate additional tracking, and monitor interaction,including interaction with the embedded content, if there is an account connected to the site. Therefore, theuser must read the Privacy Policy of the sites of origin of the contents and know their privacy policies, since
they are not the responsibility of HORIBA/TCA/HORIBA.
6.

RIGHTS OF THE WEBSITE VISITOR (USER WHO IS THE HOLDER OF PERSONAL DATA)

6.1.

The rights of personal data subjects listed in the LGPD are as follows:(i)

Access: right to request a copy of all data that HORIBA or TCA/HORIBA holds about the user.

(ii)

Confirmation of treatment: right to check whether HORIBA or TCA/HORIBA handles any
personal data of the user.

(iii)

Correction: right to ask HORIBA or TCA/HORIBA to correct outdated, incomplete, and incorrect
data. It can be done on the "Registration Update" tab.

(iv)

Anonymization, blocking or elimination: right to (a) request to have data anonymized; (b) request
blocking which temporarily suspends processing; (c) request deletion of data from the HORIBA orTCA/HORIBA database, except in cases where the law requires that they be kept.

(v)

Get informed about sharing: The user's right to know with whom their data is being shared.

(vi)

Opposition: right not to agree with the processing activities that do not depend on consent, being
able to request the interruption, unless there is a legal basis for it to be maintained by HORIBA or6

TCA/HORIBA, which must be informed to the user holder.
(vii) Portability: right to require that HORIBA or TCA/HORIBA transfer the data they have to othercompanies in the same industry.
(viii) Withdrawal of consent: right to cancel the consent granted or not to grant it, being informed of theconsequences of the choice, which may impede the activity of HORIBA or TCA/HORIBA withregards to that user.
6.2. Requests and doubts about the rights of the users must be sent via e-mail togregory.azevedo@horiba.com. In order for HORIBA or TCA/HORIBA to clarify all doubts in a completemanner, the user must identify himself and inform the right he wants to exercise, as well as direct therequest to HORIBA or TCA/HORIBA, and the Company undertakes to respond in the best time it canand according to the Brazilian law.
7.

PERSONAL DATA STORAGE AND ACTIVITY LOGGING

7.1. The personal data received by HORIBA or by TCA/HORIBA and the activities of the users are stored
in a safe and controlled place, in servers located in Brazil or in the cloud computing, and there may betransfer of data outside Brazil, provided that to companies and branches that demonstrate compliance withlegal standards, maintaining a level of compliance compatible or more stringent than that provided for inBrazilian law.
7.2. This data is stored only for as long as necessary to fulfill the defined purposes, unless there is anotherreason for keeping it, such as for complying with legal or regulatory obligations, contractual obligations,preservation of rights and legitimate interest, on the basis of the legislation in force and for the period
justified by the legal basis.
8.

FORMS OF PROTECTION OF USERS' PERSONAL DATA

8.1. To preserve the privacy of personal data handled by HORIBA or TCA/HORIBA, the Companies are
implementing internal programs that establish governance practices, standard procedures, training, andmechanisms to reduce the risks of incidents involving personal data.
8.2. Access to personal data collected in the internal environment of HORIBA or TCA/HORIBA isrestricted to properly authorized employees of each Company, always obeying the principles of
proportionality, necessity, and relevance to the purposes of the business activity, as well as the commitment
to safeguard the privacy of the user, according to this Policy.
8.3. The user is also responsible for the confidentiality of his personal data and should be aware that thesharing of access data and passwords violates this Policy and can compromise the security of the data andthe site. If the user comes to know of occurrences involving the violation of the security of his personal data,
he must contact the HORIBA/TCA/HORIBA Administrator through the service channels informed at theend of this Policy.
8.4. HORIBA and TCA/HORIBA carefully analyze their partners and service providers and establish
confidentiality, information security and personal data protection agreements, aiming at protecting therights of the user holder.
9.

ADDITIONAL INFORMATION

9.1. HORIBA or TCA/HORIBA may change the content of this Policy at any time, if they verify the needand purpose, without any notice, being the user responsible for verifying the Policy each time he/she7

accesses the website.
9.2. In the event this Policy is modified, the modifications will apply solely to personal data collected after
the revised document or privacy statement is posted on the website.
9.3. If any point of this Policy is deemed unenforceable by a judicial or data authority, this will not meanthat the entire document is null and void, and the other applicable provisions will remain in effect.
9.4. This document must be read and interpreted according to Brazilian law, in the Portuguese language,
in conjunction with the rules and procedures applicable to HORIBA and TCA/HORIBA, electing thedomicile forum of the data subject to process any controversies resulting from this Policy, unless there is a
specific determination of the legislation regarding personal, territorial, and functional competence.
10.

CONTACT

10.1. If any questions arise regarding this Policy, the user must direct them to the HORIBA andTCA/HORIBA Manager, Mr. Gregory Alan Azevedo, through the e-mail gregory.azevedo@horiba.com.
Mailing address HORIBA: Rua Presbítero Plínio Alves de Souza, nº 645, Lote Multivias, Jardim Ermida II,CEP 13.212-181. Mailing address TCA/HORIBA: Avenida Luigi Papaiz, nº 239, Setor Módulo 5, Galpão F,
Campanário Diadema - SP, CEP 09.931-610.
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