Privacy Policy

TS SHARA TECNOLOGIA DE SISTEMAS LTDA, a private legal entity registered with the Brazilian National Registry of Legal Entities (CNPJ) under No. 64.600.422/0001-80, with registered office at Rua Forte de Ribeira, 300 – Pq. Industrial São Lourenço – São Paulo – SP, values the privacy of its users/customers/suppliers/employees. Therefore, TS SHARA has created this Privacy Policy to demonstrate its commitment to the protection of personal data pursuant to the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados – LGPD), Law No. 13,709/2018, and to explain to data subjects what data is collected, how it is collected, how it is processed and stored, whether it is shared with third parties, as well as other essential information regarding personal data.

TABLE OF CONTENTS

1. GENERAL INFORMATION AND DEFINITIONS
2. DATA COLLECTION AND PROCESSING
3. DATA STORAGE
4. DATA SHARING
5. LEGAL GROUNDS FOR DATA DISCLOSURE
6. DATA RETENTION
7. DATA SUBJECT RIGHTS
8. COOKIES
9. POLICY REVISIONS
10.  CONTACT
11.  GOVERNING LAW AND JURISDICTION

1. GENERAL INFORMATION AND DEFINITIONS

User: all individuals who use or visit the Website/application/software, who are over 18 (eighteen) years of age or emancipated and fully capable of performing acts of civil life, or those who are absolutely or relatively incapable and are duly represented or assisted.

Personal Data: means any information provided to and/or collected by TS SHARA, by any means, even if publicly available, that: (I) identifies an individual or, when used in combination with other information processed by TS SHARA, identifies an individual; or (II) makes it possible to derive the identification or contact information of an individual. Personal Data may exist in any medium or format, including electronic or computerized records, as well as paper-based files. Personal Data, however, does not include business telephone numbers, business mobile telephone numbers, business addresses, or business email addresses.

Purpose: the objective or purpose that TS SHARA intends to achieve through each processing activity involving personal information.

Necessity: the justification demonstrating why the collection of personal data is strictly necessary to achieve the intended purpose, thereby avoiding excessive collection.

Legal Bases: the legal grounds that make the processing of personal data by TS SHARA legitimate for a previously defined purpose.

Consent: the express and unequivocal authorization given by the User, as the personal data subject, allowing TS SHARA to process their personal data for a previously described purpose when the applicable legal basis requires the data subject’s express authorization.

By accessing and/or using TS SHARA’s Website/application/software, the User declares that they are at least 18 (eighteen) years old and have full and express legal capacity to accept the terms and conditions of this Privacy Policy and the Consent Form for all legal purposes.

If the User does not meet the description above and/or does not agree, even partially, with the terms and conditions contained in this Privacy Policy, the User must not access and/or use any services offered by TS SHARA.

• DATA COLLECTION AND PROCESSING

The User acknowledges that they knowingly and voluntarily provide information through registration forms, websites operated by TS SHARA, or service agreements.

When the User registers and/or completes forms provided by TS SHARA, including forms available on websites operated by TS SHARA, certain requested Personal Data will be kept confidential and used only for the purposes defined below:

• DATA STORAGE

TS SHARA will store collected information on its own servers or on cloud servers provided by service providers contracted by TS SHARA.

TS SHARA uses reasonable market-standard and legally required measures to preserve the privacy of collected data. Accordingly, TS SHARA adopts precautions including:

            i. When necessary, TS SHARA uses standard, market-recognized methods to encrypt and anonymize collected data;

            ii. TS SHARA maintains protections against unauthorized access to its systems;

            iii. TS SHARA only authorizes previously designated individuals to access the locations where collected information is stored;

            iv. Individuals who come into contact with such information undertake to maintain absolute confidentiality. Any breach of confidentiality will result in civil liability, and the responsible party will be held accountable in accordance with Brazilian law.

TS SHARA uses its best efforts to preserve the privacy of Users’ data. However, no website is completely secure, and TS SHARA cannot fully guarantee that all information transmitted through its Pages will not be subject to unauthorized access through methods designed to improperly obtain information.

For this reason, we encourage Users to take appropriate measures to protect themselves, including keeping all usernames and passwords they create confidential.

• DATA SHARING

TS SHARA may share collected personal data with third parties in the following circumstances and within the limits authorized by law:

1. For administrative purposes, such as research, planning, service development, security, and risk management;
2.  For purposes related to the delivery of services contracted with TS SHARA;
3.  When necessary to comply with a legal obligation, determination of a competent authority, or court order.
4. If data is shared with third parties, the third parties and the purpose of such sharing shall be specified. 
5. Carriers and drivers will have access to sender and recipient data in order to complete deliveries. These processors may use other processors for routing and delivery planning.
6. Sender and recipient data will be shared with TMS and WMS system operators.
7. Our customers’ data will be shared with credit assessment service providers and banks responsible for payment collection.

• LEGAL GROUNDS FOR DATA DISCLOSURE

In certain cases, TS SHARA may disclose collected Personal Data in order to comply with applicable legislation or pursuant to a judicial or administrative order or subpoena.

Legal disclosure may occur in order to:

1. Comply with applicable law;
2. Investigate, prevent, or take action related to cooperation with public authorities or the protection of national security;
3. Perform contracts;
4. Investigate and defend against third-party claims;
5. Protect the security or integrity of services;

• DATA RETENTION

TS SHARA will retain information relating to Data Subjects only for the period necessary for the purposes for which such information was processed, including processing security, compliance with legal and regulatory obligations (for example, auditing, accounting, and statutory retention periods), disputes regarding processing, and the establishment, exercise, or defense of legal claims.

The Data Subject may request the deletion of their data by contacting the company directly at the email address  lgpd@tsshara.com.br or by telephone at (11) 2018-6000.

•  DATA SUBJECT RIGHTS

In compliance with applicable regulations regarding the processing of personal data, TS SHARA respects and guarantees Users the ability to submit requests based on the following rights:

i) confirmation of the existence of processing;

ii) access to personal data;

iii) correction of incomplete, inaccurate, or outdated data;

iv) anonymization, blocking, or deletion of unnecessary or excessive data or data processed in violation of applicable law;

v) portability of personal data to another service or product provider upon the User’s express request;

vi) deletion of personal data processed based on the User’s consent;

vii) obtaining information regarding public and private entities with which TS SHARA has shared the User’s data;

viii) information regarding the possibility of refusing to provide consent and the consequences of such refusal;

ix) withdrawal of consent.

TS SHARA is available to fulfill Data Subjects’ rights upon request submitted by the Data Subject via email at lgpd@tsshara.com.br or by telephone at (11) 2018-6000.

The User acknowledges that deletion of information essential to managing their account with TS SHARA will result in termination of their registration and, consequently, cancellation of the services then being provided.

TS SHARA will use its best efforts to respond to such requests as promptly as possible.

•  TS SHARA PRIVACY POLICY REVISIONS

If TS SHARA modifies this Privacy Policy, such changes will be published prominently on the TS SHARA website and, whenever possible, the Data Subject will also be informed.

• COOKIES

Cookies are files or pieces of information that may be stored on your devices when you visit TS SHARA’s Pages. A cookie generally contains the name of the website from which it originated, its lifetime, and a randomly generated value.

TS SHARA uses cookies to facilitate use of its Pages and better tailor them to Users’ interests and needs, as well as to compile information regarding the use of our websites and services, helping us improve their structure and content. Cookies may also be used to speed up Users’ future activities and experiences on the Pages.

After the User consents to the use of cookies while using the Pages of TS SHARA, TS SHARA will store a cookie on the User’s device to remember this choice during the next session.

At any time, the User may withdraw consent regarding cookies by deleting cookies from TS SHARA’s Pages using the settings of their preferred browser. For more information about managing cookies in browsers:

• Internet Explorer: https://support.microsoft.com/pt-br/help/17442/windows-internetexplorer-delete-manage-cookies
• Mozilla Firefox: https://support.mozilla.org/pt-BR/kb/ative-e-desative-os-cookies-queos-sites-usam
• Google Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop& hl=pt-BR
• Safari: https://support.apple.com/pt-br/guide/safari/sfri11471/mac

Finally, please note that if the User does not accept certain cookies used on TS SHARA’s Pages, some services may not function optimally.

1.  CONTACT

TS SHARA is available to address any questions or requests from Data Subjects via email at  lgpd@tsshara.com.br or by telephone at (11) 2018-6000.

1.  GOVERNING LAW AND JURISDICTION

This Policy shall be governed, interpreted, and enforced in accordance with the laws of the Federative Republic of Brazil, especially Law No. 13,709/2018, regardless of the laws of other states or countries. The courts of the User’s place of residence shall have jurisdiction to resolve any disputes arising from this document.