Privacy Policy

1. Introduction

TopShot Venda de Armas, Acessórios e Serviços LTDA ("we", "our", or "us"), registered under CNPJ 46.601.479/0001-12, with its principal place of business at R. São Paulo, 1781, Lourdes, Belo Horizonte - MG, 30170-135, is committed to protecting your privacy and personal data.

This Privacy Policy describes how we collect, use, store, and share your personal information in compliance with Brazil's General Data Protection Law (Lei Geral de Proteção de Dados — LGPD, Law No. 13.709/2018) and other applicable regulations.

2. Data We Collect

• Identification data: full name, CPF, RG, date of birth, nationality, marital status
• Contact data: email address, phone number, physical address
• Regulatory data: CR (Certificado de Registro), purchase authorization, SINARM/SIGMA registration
• Background data: psychological evaluation certificates, technical proficiency certificates, criminal background clearance
• Transaction data: firearm serial numbers, caliber, manufacturer, purchase logs, ammunition records
• Service data: gunsmithing work orders, maintenance records, firearm specifications
• Professional data: occupation, employer, and justification for ownership as required by regulation
• Payment data: billing information processed through secure payment systems
• Navigation data: IP address, browser type, cookies, access logs

3. How We Use Your Data

• Processing firearm, ammunition, and accessory sales per federal regulations
• Verifying customer eligibility and required documentation
• Registering transactions with SINARM and SIGMA as mandated by law
• Managing CR registration and authorization renewal assistance
• Processing gunsmithing and maintenance service orders
• Maintaining legally required traceability and transaction logs
• Processing payments and issuing invoices (NF-e)
• Providing safety training and responsible ownership guidance
• Reporting to authorities as required by the Statute of Disarmament

4. Legal Basis for Processing

• Compliance with legal or regulatory obligations (primary basis for firearms data)
• Performance of a contract or preliminary procedures related to a contract
• Consent provided by the data subject
• Legitimate interests of the controller, provided fundamental rights are preserved

5. Data Sharing

• Brazilian Army (Exército Brasileiro) for SIGMA registration and compliance reporting
• Polícia Federal for SINARM registration and transaction records
• Firearm manufacturers for warranty registration and recall coordination
• Payment processors for secure transaction handling
• Technology service providers for system maintenance
• Tax authorities as required by fiscal regulations
• Law enforcement and judicial authorities when required by law

6. Data Retention

Personal data is retained for the periods mandated by applicable firearms regulations, which may exceed standard commercial retention periods. Transaction records, serial numbers, and buyer identification data are retained as required by the Statute of Disarmament. Gunsmithing records are retained for traceability purposes. Fiscal data is retained per tax regulations. Regulatory retention requirements supersede deletion requests until mandatory periods expire.

7. Your Rights

Under the LGPD, you have the following rights:

• Confirmation of the existence of data processing
• Access to your personal data
• Correction of incomplete, inaccurate, or outdated data
• Anonymization, blocking, or deletion of unnecessary or excessive data
• Portability of data to another service provider
• Deletion of data processed with your consent
• Information about entities with which your data has been shared
• Information about the possibility of denying consent and its consequences
• Revocation of consent

Certain rights may be limited where processing is mandated by law, particularly for firearms transaction records. To exercise your rights, contact us at Section 10.

8. Cookies

Our website may use cookies and similar technologies to enhance your browsing experience. You may configure your browser to refuse cookies; however, some features may not function properly without them.

9. Data Security

We maintain stringent technical and organizational measures to protect personal data, including restricted physical access, encrypted digital storage, strict access controls, and regular security assessments appropriate to the sensitive nature of firearms commerce. Despite our efforts, no method of electronic transmission or storage is completely secure.

10. Contact Information

11. Changes to This Policy

We reserve the right to update this Privacy Policy at any time, including in response to changes in firearms regulations. Changes will be posted on this page with a revised "Last updated" date.