Privacy Policy

1. Data controller

TWS Maritime Service Ltda. is the controller of personal data processed through this website and through corporate or pre-contractual relationships initiated via its digital channels.

This Policy explains, in clear terms, the data we may process, why we use it, when it may be shared, and which rights may be exercised under the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais – LGPD).

2. Data we may process

Depending on how you interact with TWS, we may process:

• identification and contact data, such as name, email address, telephone number, position, and company;
• request details, such as the required service, vessel, cargo, port or location, preferred date, and message content;
• technical and security data, such as IP address, date and time, access logs, browser information, and events required to protect the website;
• authorized-user data where access to an administration panel or restricted area is provided;
• other information voluntarily supplied during subsequent communications.

Please do not submit excessive personal data, sensitive personal data, or documents that are not required for the initial contact.

3. Purposes and legal bases

Personal data may be used to:

• respond to messages, assess availability, prepare quotations, and take steps prior to an engagement;
• perform contracted services and manage relationships with clients, representatives, and partners;
• comply with legal, regulatory, tax, and contractual obligations;
• protect rights, prevent fraud, maintain security, and preserve evidence of communications;
• improve the website, attendance processes, and service quality;
• send relevant corporate communications where an appropriate legal basis exists and an opt-out is available.

Depending on the circumstances, processing may rely on steps prior to entering into a contract, performance of a contract, compliance with a legal or regulatory obligation, the exercise of legal rights, a responsibly assessed legitimate interest, or consent.

4. Sharing

TWS does not sell personal data. Information may be shared only where necessary with:

• hosting, email, security, support, and other technology providers;
• professional advisers subject to confidentiality duties;
• operational partners involved in an attendance where authorized, instructed, or required to perform the service;
• public authorities, regulators, or third parties where required by law or necessary to protect legal rights.

Some technology providers may process data outside Brazil. Where this occurs, we seek to use reputable providers and mechanisms consistent with the rules applicable to international data transfers.

5. Retention and deletion

Personal data is retained only for as long as required for the purposes described above and for applicable legal, regulatory, contractual, or claims-related periods. When it is no longer required, it will be deleted or anonymized unless retention is permitted or required by law.

6. Security

We use reasonable technical and administrative controls to reduce the risk of unauthorized access, loss, alteration, or improper disclosure. No digital environment is risk-free, and our processes and safeguards are reviewed as the website evolves.

7. Data-subject rights

Subject to the LGPD and the circumstances of each request, a data subject may request:

• confirmation that processing takes place and access to personal data;
• correction of incomplete, inaccurate, or outdated data;
• anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
• portability, subject to regulation and the protection of commercial and industrial secrets;
• information regarding sharing and the ability to refuse or withdraw consent;
• review of decisions based solely on automated processing, where applicable;
• submission of a complaint to the Brazilian National Data Protection Authority (ANPD).

To protect the data subject, we may request reasonable information to verify identity. Requests should be submitted using the email address shown in the website footer.

8. Updates and contact

This Policy may be updated to reflect legal, operational, or technological changes. The date displayed on this page identifies the current version. Privacy questions and data-subject requests may be sent through the contact channel published in the footer.