Privacy Policy

Source of Personal Data

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA will have access to personal data in the following situations:

• Through interaction with a customer: When the Customer provides and inputs personal data necessary for the provision of services and use of products provided by POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA
• Interaction with its employees: When its employees and collaborators of any nature use its systems and platforms to comply with the duties and obligations arising from the contractual relationship they have.

2. Types of personal data and sensitive personal data collected

Without prejudice to the commonly collected and processed data of its employees for the purposes of the legal relationship they have, POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA may also collect the following personal data:

• Names and contact data, such as first and last name, email address, postal address, telephone number and other similar types of contact data, such as bank details;
• Device information, such as information about your device such as IP address, location or provider;
• Usage information and browsing history, such as information about how the User navigates within our services, their browsing history and which elements of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA services are most used;
  
  

Sensitive personal data that may eventually be collected by POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA will have their purpose informed separately to the User, who must consent for POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA to use them in a specific manner, and in case of disagreement, the data will be automatically deleted from the bases of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA does not collect data from minors, except with the authorization of parents or guardians, if collected without authorization, as soon as POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA becomes aware of it, it will immediately delete the data collected, in accordance with rules of the Terms of Use and this Privacy Policy.

3.Use of personal data collected

When collected, POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA will use personal data to:

• Provide and improve contracted services;
• Comply with a legal or regulatory obligation;
• Manage the relationship with Users;
• Configure and manage User accounts;
• Provide technical assistance, support and training to the User;
• Contact Users;
• Internal research and development purposes and to improve, test and perfect the features and functions of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA services;
• Provide Users with marketing, advertising, advertising, including POSEIDON CONTAINER SHIPPING AND NAVEGACAO LTDA Partner companies, as permitted by law;
• Meet internal and external audit requirements, including information security obligations of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA;
• Send messages by email to: a) confirm or cancel requests through the use of the platform; b) communicate future changes that this policy may undergo; and c) disclose updates, changes, additions of new data sources and improvements to the platform.
• To exercise the rights of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA, including but not limited to the privacy, security, networks, systems and properties of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA and/or third parties;
• Comply with requests from courts, police authorities, regulatory bodies and other public institutions and government authorities, including, but not limited to, any rules in force outside the user’s country of residence;
• The exercise of the rights of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA and to defend itself against any legal actions, as well as for compliance with any legislation or regulation applicable to POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA or third parties with whom we work, as well as for the exercise of the proper fulfillment of contracts signed between POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA and its users;

4. Sharing of personal data with third parties

The User accepts and agrees that POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA shares his personal data with the following recipient categories:

• Companies that provide access or are responsible for the registration on which the user is dependent;
• Partner companies, such as third-party service providers and other companies that assist us in offering our services or that can take action on our behalf, protecting our rights, users, systems and services;
• Third parties to which POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA owes satisfaction or is authorized to disclose information by law (Example: government agencies, regulatory agencies, judiciary and other public authorities);
• Third parties in order to participate in the sale, merger, acquisition, restructuring, joint venture, assignment, transfer of part or all of the business of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA in which case the User’s data will be considered an asset and transferred in an eventual negotiation;
• Third parties who need the data to protect the rights of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA;

Any natural or legal person for whom the User requests the portability of their data.

5. International transfer of personal data

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA does not intend to carry out the transfer of any personal data of the User captured outside Brazil, being certain that if the hypotheses listed below are not met, Users will be previously informed by e-mail, at which time the user may or may not accept the transfer, and in case of disagreement, he may have his access rights prevented by POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA.

The international transfer of data described in the General Data Protection Law (LGPD) lacks the designation of guidelines to be established by the National Authority for the Protection of Personal Data (ANPD), whereas, when defined, POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA will undertake to comply with them in their entirety.

6. Protection of personal data

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA uses appropriate technologies and procedures to protect any personal data collected (including administrative, technical and physical protections) according to the level of risk and the service provided, having a legally responsible team to deal with secure management of data in line with legal provisions, regulatory requirements, changes in technology, among other relevant factors that may influence the way to protect personal data.

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA employs all reasonable market efforts to ensure the security of its systems and the data collected, using highly qualified and reputable Internet providers and database and storage servers, in addition to security certificates (SSL ) and software to protect against unauthorized access to systems, as well as standard methods for encrypting and anonymizing collected data.

This Policy represents POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA’s efforts to safeguard User information. However, due to the very nature of the Internet, it is not possible to guarantee that malicious third parties will not succeed in improperly accessing the stored information, which is why, in the event that this occurs, POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA will be responsible within the limits provided for in Law.

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA, within a reasonable period to be defined by the National Data Protection Authority (“ANPD”), shall notify the ANPD and the affected User of the occurrence of a security incident that may entail significant risk or damage to the affected User , mentioning at least:

• a description of the nature of the affected personal data;
• information on the holders involved;
• indication of the technical and security measures used to protect data, observing commercial and industrial secrets;
• the risks related to the incident;
• the reasons for the delay, in case the communication was not immediate; It is
  the measures that have been or will be adopted to reverse or mitigate the effects of the loss.

7. Data processing and liability of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA.

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA will be responsible for the treatment as follows:

• When dealing with personal data provided directly by its Customers, POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA will be the Operator, and will act without interference in the form of treatment indicated by the Controller, but under the terms of the LGPD;
• POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA will be the Controller of the Personal Data of its employees, treating them based on the Execution of Contracts, Compliance with legal or regulatory obligations, and also, in specific and determined situations, on Consent.

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA may adopt different legal bases for different processing of personal data.

8. Period of processing of personal data

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA calculates the retention period of personal data according to the following criteria:

• Period necessary to fulfill the purpose of the collection;
• The moment when the Client/User stops using the services of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA;
• The moment when consent is revoked or request for deletion of personal data by the Holder;
• The time required to demonstrate compliance with the duties and obligations of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA;
• The necessary period provided for by law, regulations, court decisions, etc.;
• Determination of the National Data Protection Authority;
• Compliance with a legal or regulatory obligation by the Controller;
• Perfect performance of the contract;
• Needs related to compliance with the legal system, as well as for any legal disputes;
• Transfer to a third party, provided that the requirements for data processing provided by law are respected; or

Exclusive use of the controller, access by a third party is prohibited, and provided that the data is anonymised.

According to the Brazilian General Data Protection Law, the User will have the following rights regarding the processing of their personal data:

• Right of Confirmation: the User may confirm whether POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA processes any of his/her personal data;
• Right of Access: the User may make a written request to obtain details of how their information is being used, as well as to have a copy of said information;
• Right to Correction: the User may correct or remove any data that is incomplete, inaccurate or out of date;
• Right of anonymization, blocking or deletion: the User may request the anonymization, blocking or deletion of data that is unnecessary, excessive or treated in disagreement with the purposes for which he/she has given consent, observing, for this purpose, other rules of the legal system;
• Right of Exclusion: the User may request the exclusion of some data, except those in which the law authorizes its conservation;
• Right of Information: The User may request information from public and private entities with which POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA carried out the shared use of their data, as well as the consequences if they choose not to consent to the collection and processing of their personal data;
• Right to Refuse Marketing: The User may, at any time, request the cancellation of receiving advertisements and other materials through the link provided in the marketing email sent.
• Right of Portability: The User may request that their personal data be transferred to themselves or third parties, except for those that have already been anonymized and deleted by POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA.
• Right to Withdraw Consent: Users may cancel any consent previously granted to POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA to use their personal data. The User is aware that the cancellation will not affect the use or sharing of data carried out prior to the request for revocation of consent.

The rights provided for in this chapter are not absolute, and the User must, whenever he wants to exercise them, contact POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA through the

channel: marketing01@poseidon-cs.com

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA undertakes to respond to such requests as soon as possible and at no cost to the User, limited to a maximum period of 15 (fifteen) days, counting from the receipt of the request, unless necessary a longer period for

respond due to the complexity, reasons of fact or law, opportunity in which the User will be communicated.

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA will immediately notify the processing agents with which it has shared User data about the correction, deletion, anonymization or blocking of the data, so that they can repeat the same procedure.

Confirmation of existence or access to the User’s personal data provided for in this chapter will be provided, electronically or expressly, in a simplified format or by means of a clear and complete statement, which indicates the origin of the data, the lack of registration, the criteria used and the purpose of the treatment, always observing the commercial and industrial secrets of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA.

10.Cookies

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA and any partners may use cookies and other similar technologies to store and manage User preferences, offer targeted advertising, enable content and collect analytical and usage data, for example. The use of cookies and other tracking technologies is a standard on websites and platforms, through which information about User activities on the platform, websites or other services is collected.

A cookie is a small text file, placed on a computer or other device, used to identify the User, device used and to collect information and can perform the following functions:

• Necessary Cookies: These are essential to allow the User to browse a platform and use its resources.
• Performance Cookies: they collect information on how the User uses the POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA platform and serve to improve your navigation and enhance your experience. The information collected includes, for example, internet browsers and operating systems used, the domain name of the previously visited website, the number of visits, the average duration of the visit and the pages viewed.
• Functional Cookies: they allow the platform to remember choices the User has made (such as their username or ID, language preference or the area or region where the User is located) and provide enhanced and more personal features.
• Advertising Cookies: they track the User’s browsing habits and are used to provide targeted advertising. These cookies also limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns. They also remember that the User has already visited a website and this information is shared with other organizations, such as advertisers.

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA uses necessary and performance cookies.

At any time, the User may disable Cookies through his browser settings, installing plug-ins available on the market, or even making use of other technologies that he deems necessary.

In addition to cookies, POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA uses other tracking technologies, such as:

Web Server and Platform Records: POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA servers automatically collect certain information to assist, administer and

protect the services offered, as well as to analyze usage and improve the User experience. Information collected includes:

• IP address and browser type;
• Device information, including the Unique Device Identifier (UDID), MAC address, Identifier for Advertisers (IFA) and similar identifiers assigned by us or third parties;
• The device’s operating system and other technical data;
• The city, state and country from where you are accessing the BRASIL RISK platform, including for fraud prevention;
• Typed information or texts;
• Links and buttons clicked;

Connections via Social Networks: Some of the services of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA may include social network features, such as Facebook “Like” buttons and widgets; “Share” button and interactive mini-programs.

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA may allow the User to choose to use the logins of their own social networks to access some of the services offered, in which case POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA may receive and store authentication information for these services.

11. Contact information

Questions, comments, suggestions and/or complaints regarding this Privacy Policy, as well as any need for information, alteration or deletion of personal data, may be made by the User directly to POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA, by email: marketing01@ poseidon-cs.com

12. Changes

POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA seeks constant updates and improvements, so this Privacy Policy may be updated at any time, always aiming at better provision and protection for users.

In the event of changes that affect the purpose and duration of the processing of the User’s personal data, the User will be informed through the e-mail registered in our services or through the platform itself 30 (thirty) days in advance. If there is disagreement with the changes, the User may revoke the consent provided, being unable to use the services of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA.

If, in the future, POSEIDON CONTAINER SHIPPING AND NAVEGACAO LTDA changes its policy with a view to sharing data with third parties, it will forward a communication 30 (thirty) days in advance to the user via the registered e-mail, who may disagree with the sharing, at which time you will continue to use the services of POSEIDON CONTAINER SHIPPING E NAVEGACAO LTDA.

The User is advised to periodically read this policy to keep up to date with its content.

12. Legislation and jurisdiction

This Policy will be governed, interpreted and enforced in accordance with the laws of the Federative Republic of Brazil, regardless of the conflicts of these laws with laws of other states or countries, being

The Forum of São Paulo is competent to resolve any doubts arising from this instrument, waiving any other, however privileged it may be.

All rights reserved.