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We have detected that you are in the United States based upon your IP address, if you are not in the United States, please select your country for the correct Terms of Use for your region. Alcon as a Data Processor - Product and Services Annex English (U.S.) English (U.S.) English (U.S.) Czech (Czech Republic) Czech (Czech Republic) Dutch (Netherlands) Dutch (Flemish (Netherlands) French Français German Deutsch Hungarian (Hungary) Hungarian (Hungary) Italian Italiano Japanese (Japan) Japanese (Japan) Korean (South Korea) Korean (South Korea) Polish Polski Portuguese (Brazil) Português (Brasil) Portuguese (Portugal) Portuguese (Portugal) Slovak (Slovakia) Slovak (Slovakia) Spanish (Argentina) Spanish (Argentina) Spanish (Spain) Spanish (Spain) Turkish (Turkey) Turkish (Turkey) Introduction I. Surgical 1.1. Installation, maintenance, remote maintenance, remote technical supportremote connectivity, software updates, repairs and removal of Alcon surgical equipment 1.2. Evaluations of Alcon surgical equipment 1.3. IOL calculations 1.4. MyAlcon Surgical Store/ Adi Store II. Vision Care 2.1. Marlo – no direct to patient delivery or patient management (applies to Customers in e.g. Turkey, France, Brazil, South Africa) 2.2. Marlo B2B with direct to consumer/patient deliveries and consumer/patient management option 2.3. Marlo B2B2C (functionality available in certain markets only, e.g. Italy, Japan) 2.4. Superstores Introduction Introduction I. Surgical 1.1. Installation, maintenance, remote maintenance, remote technical supportremote connectivity, software updates, repairs and removal of Alcon surgical equipment 1.2. Evaluations of Alcon surgical equipment 1.3. IOL calculations 1.4. MyAlcon Surgical Store/ Adi Store II. Vision Care 2.1. Marlo – no direct to patient delivery or patient management (applies to Customers in e.g. Turkey, France, Brazil, South Africa) 2.2. Marlo B2B with direct to consumer/patient deliveries and consumer/patient management option 2.3. Marlo B2B2C (functionality available in certain markets only, e.g. Italy, Japan) 2.4. Superstores Alcon is offering products and services to Customers which may involve the processing of personal data. This Annex serves as an overview of where Alcon is acting as a data processor. Alcon may be acting as well as data controller when providing products and services. Please refer to our Privacy Notices for more information. I. Surgical 1.1. Installation, maintenance, remote maintenance, remote technical supportremote connectivity, software updates, repairs and removal of Alcon surgical equipment Purpose of processing on behalf of the Customer Providing initial installation support for the surgical equipment, maintenance, software updates, upgrades, corrective services, technical support, repairs, removal, replacement Categories of data subjects whose personal data is processed Patients Customer staff (including Health care professionals) Categories of personal data processed Depending on the surgical equipment device, different personal data may be in scope including healthcare professional usage data and patient health data. Nature of the processing Managing, copying, deleting, accessing, viewing Duration of the processing For the duration of Alcon’s service contract and the surgical equipment’s warranty Processor locations Your local Alcon entity is the Processor Sub-processors Other Alcon entities within the worldwide Alcon group may be engaged as sub-processors. Alcon has a Data Privacy Intragroup Agreement which includes the legally required data processing and data transfer clauses. Securelink Online Screen Assist (managed by Santec in partnership with ISL Online) AWS (where hosting services are provided to Customer) Purpose of Sub-processor’s processing Other Alcon entities:provide input, analysis and technical support as needed Securelink: enable remote access and software updates Online Screen Assist: enable remote access and software updates AWS: hosting services Sub-processor locations Other Alcon entities: worldwide Securelink: AWS Virginia Online Screen Assist: worldwide AWS: 1.2. Evaluations of Alcon surgical equipment Purpose of processing on behalf of the Customer Enabling the Customer to conduct evaluations of Alcon surgical equipment. Alcon personnel can be present during surgeries and incidentally view personal data. Alcon personnel could be requested to provide assistance for how to operate the equipment device including related to a specific patient case. At the end of the evaluation, Alcon personnel could be requested by Customer to provide assistance for copying personal data contained on the equipment device and purging the equipment device thereafter of any personal data. Categories of data subjects whose personal data is processed Patients Customer staff (including Health care professionals) Categories of personal data processed Depending on the surgical equipment device, different personal data may be in scope including healthcare professional usage data and patient health data. Nature of the processing Copying (as described above), deleting, viewing Duration of the processing For the duration of the evaluation until removal of the equipment device Processor locations Your local Alcon entity is the Processor Sub-processors Other Alcon entities within the worldwide Alcon group may be engaged as sub-processors. Alcon has a Data Privacy Intragroup Agreement which includes the legally required data processing and data transfer clauses. Purpose of Sub-processor’s processing Other Alcon entities: provide Alcon personnel where local Alcon entity personnel needs support/additional expertise Sub-processor locations Other Alcon entities: worldwide 1.3. IOL calculations Purpose of processing on behalf of the Customer Provide optional IOL cross check support to HCPs. This allows HCPs to request a second, non-binding evaluation of IOL parameters they have already assessed for a given patient. The purpose of this process is to: confirm HCP evaluations, provide additional education insights, and enhance confidence in IOL selection. Categories of data subjects whose personal data is processed Patients Categories of personal data processed Patients age, physical characteristics, retina scan, eye diagnostics and measurements, Intraocular lens (IOL) product details and measurements, eye health information, behaviors or habits, specific health condition Nature of the processing Receiving, analyzing, managing, storing, transmitting and otherwise processing Duration of the processing Alcon removes once the post-op is finished and once Alcon has checked the patient's situation via the HCP. Processor locations Your local Alcon entity is the Processor Sub- processors Other Alcon entities within the worldwide Alcon group may be engaged as subprocessors. Alcon has a Data Privacy Intragroup Agreement which includes the legally required data processing and data transfer clauses. Microsoft Purpose of Sub-processor’s processing Other Alcon entities: provide input, analysis and other support as needed Microsoft: Providing for storage and communication tools Sub-processor locations Other Alcon entities:worldwide Microsoft: Hosting provided for in Germany 1.4. MyAlcon Surgical Store/ Adi Store Purpose of processing on behalf of the Customer Manage IOL orders and consignment, maintain Customer inventory Categories of data subjects whose personal data is processed Patients Categories of personal data processed Pseudonymous patient health data, biometrics, IOL product details and measurements Nature of the processing Collecting, managing, storing, accessing, deleting Duration of the processing As long as necessary for the purpose and per Data Controller’s instructions Processor locations Your local Alcon entity is the Processor Sub- processors Other Alcon entities within the worldwide Alcon group may be engaged as sub-processors. Alcon has a Data Privacy Intragroup Agreement which includes the legally required data processing and data transfer clauses. SAP United States Salesforce.com in multiple locations worldwide Purpose of Sub-processor’s processing Other Alcon entities: provide product stock management, product shipment, analysis and other support as needed Sub-processor locations Other Alcon entities: worldwide II. Vision Care 2.1. Marlo – no direct to patient delivery or patient management (applies to Customers in e.g. Turkey, France, Brazil, South Africa) Purpose of processing on behalf of the Customer Providing eye-care professionals (eye doctors or opticians) with a simple and convenient ordering experience for Alcon Vision Care products for their patients Categories of data subjects whose personal data is processed Consumers Categories of personal data processed De-identified consumer health data (contact lenses corrections, eye diagnostics and measurements, internal consumer number attributed by Customer) Nature of the processing Collecting, managing, using, storing, accessing, deleting Duration of the processing As long as necessary for the purpose and per Data Controller’s instructions Processor locations Your local Alcon entity is the Processor Sub- processors Other Alcon entities within the worldwide Alcon group may be engaged as subprocessors. Alcon has a Data Privacy Intragroup Agreement which includes the legally required data processing and data transfer clauses. Commercetools AWS Purpose of Sub-processor’s processing Other Alcon entities: provide product stock management, product shipment, analysis and other support as needed Commercetools: Managing of Marlo platform AWS: Hosting Sub-processor locations Other Alcon entities: worldwide Commercetools: Germany AWS: Germany 2.2. Marlo B2B with direct to consumer/patient deliveries and consumer/patient management option Purpose of processing on behalf of the Customer Providing eye-care professionals (eye doctors or opticians) with a simple and convenient ordering experience for Vision Care products (contact lenses, contact lens care and dry eye products (where available)). Eye-care professionals may with the consent of their consumers use direct to consumer deliveries and manage consumer data between different orders in Marlo. Categories of data subjects whose personal data is processed Consumers Categories of personal data processed Patient/consumer data: names, addresses, email or phone number, patient health data (contact lenses corrections, eye diagnostics and measurements, internal consumer number attributed by Customer) Nature of the processing Collecting, managing, using, storing, accessing, deleting Duration of the processing As long as necessary for the purpose and per Data Controller’s instructions Processor locations Your local Alcon entity is the Processor Sub- processors Other Alcon entities within the worldwide Alcon group may be engaged as subprocessors. Alcon has a Data Privacy Intragroup Agreement which includes the legally required data processing and data transfer clauses. Commercetools AWS Purpose of Sub-processor’s processing Other Alcon entities: provide product stock management, product shipment, analysis and other support as needed Commercetools: Managing of Marlo platform AWS: Hosting Sub-processor locations Other Alcon entities: worldwide Commercetools: Germany AWS: Germany 2.3. Marlo B2B2C (functionality available in certain markets only, e.g. Italy, Japan) Purpose of processing on behalf of the Customer Providing eye-care professionals (eye doctors or opticians) and consumers with a simple and convenient ordering experience for Vision Care products (contact lenses, contact lens care and dry eye products (where available)). Eye-care professionals may, with the consent of their consumers, add their health data in Marlo. Consumers may directly manage their orders and related information in Marlo. Categories of data subjects whose personal data is processed Consumers Categories of personal data processed Patient data: names, addresses, email, phone number, patient health data (contact lenses corrections, eye diagnostics and measurements, internal consumer number attributed by Customer), payment information Nature of the processing Collecting, managing, using, storing, accessing, deleting Duration of the processing As long as necessary for the purpose and per Data Controller’s instructions Processor locations Your local Alcon entity is the Processor Sub- processors Other Alcon entities within the worldwide Alcon group may be engaged as subprocessors. Alcon has a Data Privacy Intragroup Agreement which includes the legally required data processing and data transfer clauses. Commercetools AWS Purpose of Sub-processor’s processing Other Alcon entities: provide product stock management, product shipment, analysis and other support as needed Commercetools: Managing of Marlo platform AWS: Hosting Sub-processor locations Other Alcon entities: worldwide Commercetools: Germany AWS: Germany 2.4. Superstores Purpose of processing on behalf of the Customer Alcon is offering a service to Customers to analyze the patient journey in the respective Customer’s practice. For this analysis, aggregated data is needed which the Customer needs to enter into the application tool provided by Alcon. In order to enter the aggregate data into the application, it is necessary to consult Customer’s individual patient records. Customer may ask Alcon staff to take on this activity at the Customer’s site. Categories of data subjects whose personal data is processed Consumers Categories of personal data processed Patient data: names, addresses, email, phone number, patient health data (such as contact lenses corrections, eye diagnostics and measurements, other medical information), patient treatment journey Nature of the processing Collecting, managing, using, storing, accessing Duration of the processing As long as necessary for the purpose and per Data Controller’s instructions Processor locations Your local Alcon entity is the Processor Sub- processors Not applicable Purpose of Sub-processor’s processing Not applicable Sub-processor locations Not applicable February 16, 2026 (3:13 pm)