TTW BRASIL OPERACOES TURISTICAS LTDA. (“TTWGROUP”) has established this Privacy and Data Security Policy (“Privacy Policy”) as part of a set of actions that aim to protect your privacy and preserve the right to confidentiality of each user’s identity.
This Privacy Policy provides information about the automated and non-automated processing of personal data carried out, and its purpose; what personal data is necessary to provide the service; the way the data are collected; whether your data is shared with third parties; and what security measures are implemented to protect your data.
The Privacy Policy was prepared in accordance with Brazilian Federal Law No. 12,965, of April 23, 2014 (Marco Civil da Internet), and with Brazilian Federal Law No. 13,709, of August 14, 2018 (General Law for the Protection of Personal Data – LGPD), in compliance with the principles set out in art. 6:
I – purpose: carrying out the processing of data for specific and explicit purposes that are disclosed to the holder;
II – consistency: compatibility of the processing of data with the purposes disclosed to the holder;
III – necessity: limitation of the processing if data to the minimum necessary to achieve its purposes, with coverage of pertinent data kept proportional and not excessive in relation to the purposes of data processing;
IV – free access: guarantee of easy and free consultation for data subjects regarding the form and duration of processing, as well as the completeness of their personal data;
V – data quality: the guarantee to data subjects, of the accuracy, clarity, relevance and updating of data as needed in order to process it;
VI – transparency: the guarantee of clear, precise and easily accessible information about the data processing carried out and about the agents handling the processing;
VII – security: the use of security measures to protect personal data from unauthorized access and accidental or illicit misuse leading to the destruction, loss, alteration, release or dissemination of the data;
VIII – non-discrimination: data processing may not be carried out for illicit or abusive discriminatory purposes.
- Acceptance of the Terms of Use and Privacy Policy
By using the services, you confirm that you have read and understood the Terms of Use and Privacy Policy applicable to the requested service and agree to be bound by them.
- Definitions
For the purposes of this Privacy Policy, the following definitions apply:
Database: Structured set of personal data, established in one or more locations, on electronic or physical media.
Malicious code: any computer program, or part of a program, built with the intention of causing damage, obtaining unauthorized information or interrupting the functioning of computer systems and/or networks.
Cookie: a text file sent by the website server to the user’s computer, with the purpose of identifying the computer, personalizing the user’s access and obtaining access to data, such as pages browsed or links clicked. A cookie is assigned individually to each computer, and it cannot be used to run programs or infect computers with viruses; it can only be read by the server that sent it.
Not every cookie contains the user’s personal data, since certain types of cookies are only used to ensure the service works properly.
The information stored in cookies is also considered personal data and all the rules set out in this Privacy Policy are also applicable to them.
The customer can disable the saving of cookies in their browser, delete them or manage their use through the configuration of the browser they use to access our websites.
Individual identification: all information that is not available to the general public, and that, if disclosed, could cause some type of moral embarrassment, harm or harm to the person themselves. Examples of individual identification data include ID numbers, CPF numbers, contact details and billing details.
Internet: the system consisting of a set of logical protocols, structured on a global scale for public and unrestricted use, with the purpose of enabling data communication between terminals through different networks.
General Personal Data Protection Law (LGPD): Brazilian Federal Law no. 13,709, of August 14, 2018, which provides for the processing of personal data, including in digital media, by natural persons or legal entities governed by public or private law, with the aim of protecting the fundamental rights of freedom and privacy and the free development of the personality of the individual.
Remarketing: is a resource with which an advertiser (in this case TTWGROUP) can reach people who previously visited their website and display relevant advertisements across the web or when an internet search site is used.
Websites and applications: Websites are a set of pages available on the internet, and applications are software that perform a group of functions with the aim of providing a service to users.
Third party: Person or entity that does not directly participate in a contract, in a legal act or in a business, or who, in addition to the parties involved, may have an interest in a legal process.
Holder: individual to whom the personal data that is subject to processing refers.
Processing: any operation carried out with personal data, such as those relating to collection, production, reception, classification, use, access, reproduction, transmission, distribution, treatment, archiving, storage, elimination, evaluation or control of information, modification, communication , transfer, diffusion or extraction.
Shared use of data: communication, dissemination, international transfer, interconnection of personal data or shared processing of personal databases by public bodies and entities in compliance with their legal powers, or between them and private entities, reciprocally, with specific authorization, to one or more treatment modalities permitted by these public entities, or private entities.
User: every person who, in some way, accesses the website, whether they are a customer or not.
- User rights
The user has the right to adequate provision of services, which must be offered in accordance with guidelines such as respect; equal treatment without any type of discrimination; accessibility; compliance with deadlines and standards; and adequacy between means and ends – without the imposition of requirements, obligations, restrictions and sanctions not provided for in legislation.
The processing of personal information must be carried out in a transparent manner and with respect for privacy, personal life, honor and personal image, as well as individual freedoms and guarantees.
- Responsibilities
The user is responsible for the accuracy and veracity of the data provided and acknowledges that their inconsistency may result in the impossibility of using the requested service.
The user undertakes to provide only their personal data, and not that of third parties.
The user is responsible for repairing any and all damages, direct or indirect (including resulting from violation of any rights of other users, third parties, intellectual property rights, confidentiality and personality), that are caused to TTWGROUP, to any another User, or even any third party, as well as due to non-compliance with the provisions of this Terms of Use and Privacy Policy or any act carried out after accessing the service.
- Obligations
TTWGroup is committed to:
5.1. Collect on our website only the individually identifiable information necessary to run our business and provide products and/or services requested by users;
5.2. Use cookies to provide a better experience on TTWGroup websites and enable personalized features such as advertising and additional information on items of interest to the customer, for example;
5.3. Strictly comply with all provisions of this Privacy Policy.
- Use of Information
The information obtained through the website will be used by TTWGroup for the purposes, including but not limited to:
- Enabling the provision of products or services requested on the websites;
- Identifying the profile, desires or needs of users, in order to improve the products and/or services offered;
- Sending information about products or services that interest our users;
- Publicizing changes, innovations or promotions about the products and services of the company TTWGroup and its partners.
TTWGROUP uses interest-based advertising campaigns, remarketing lists, demographic and target location information on all of our websites. Such advertising campaigns do not associate individual identifiers with remarketing lists, cookies, feed data or other anonymous identifiers. Likewise, resources applied to campaigns are not associated with information collected on TTWGROUP website pages and advertisements.
Individually identifiable information is not shared with any website or partner through the remarketing tag or any data feed that may be associated with TTWGROUP ads.
TTWGROUP will not be responsible for any loss of user data, including those resulting from acts of God, events of force majeure, occurring due to intrusions into the website and breach of security by unauthorized third parties.
- Data Disclosure
TTWGROUP does not provide data on the individual identification of users to third parties without their prior consent, except in cases where:
– There is a court order to provide data;
– The viability of the business and/or services offered by TTWGROUP depends on the transfer of data to partners;
– There is a need to identify or reveal data of users who are using their websites for illegal purposes (intentionally or not);
– In addition to the cases mentioned above, if there is a need or interest in passing on users’ individual identification data to third parties, TTWGROUP will request prior authorization;
- Third parties who may receive information of any nature from TTWGROUP about users are also responsible for ensuring the confidentiality and security of said information.
- User Responsibilities
The User is fully responsible for:
– Taking care of your individual digital identification data whenever you access the Internet, and informing them only in operations where data protection exists;
– Providing truthful information;
– Strictly complying with all determinations and procedures set out in this Privacy Policy.
- Change in Privacy Policy
TTWGROUP may change this Privacy Policy at any time, and any changes to this Privacy Policy will be published in this space.
- Questions and Suggestions
If you have any questions or suggestions about this Privacy Policy, write to: contact@ttwgroup.com
- Unsubscribing
TTWGroup is committed to respecting your privacy and is against spam. For this reason, we undertake to: (i) not send promotional emails without your express prior consent given at the time of registration; (ii) immediately cancel the sending of promotional emails whenever requested; (iii) use cookies (information sent by the website to your computer to identify you) only so that the website can recognize you when you make a new visit. Acceptance of the cookie is not necessary to visit the website. Your browser can be configured to warn you whenever a cookie is offered or to refuse all cookies
- Disclaimer
TTWGROUP cannot be held responsible for the following situations:
- Equipment infected or invaded by attackers;
- Equipment damaged when using services;
- Protection of information contained on users’ computers;
- Abuse of use of users’ computers;
- Clandestine monitoring of users’ computers
- Vulnerabilities or instabilities existing in user systems.
Under no circumstances will TTWGROUP be responsible for the installation of malicious codes (viruses, trojans, malware, worms, bots, backdoors, spyware, rootkits, or any others that may be created) on its equipment or on third parties’ equipment, as a result of Internet browsing by the User.
You agree that you will not use robots, scanning and data storage systems (such as “spiders” or “scrapers”), hidden links or any other questionable resource, tool, program, algorithm or automatic data collector/extractor method to access, acquire , copy or monitor the service, without express written permission from the agency.
TTWGROUP may provide the information technology service provider with the contact details of users who, in breach of the Terms of Use and Privacy Policy, use robots, scanning and data storage systems (such as “spiders” or “scrapers” ), hidden links or any other hidden resource, tool, program, algorithm or automatic data collector/extractor method to access, acquire, copy or monitor the service, for the purpose of providing guidance on technological solutions that prevent the degradation of the computerized environment, and may even restrict access to content temporarily.
By agreeing to this Terms of Use and using the mobile application, you will receive permission from the agency for non-commercial use of the services offered by the application, which, under no circumstances, will make you the owner of the mobile application.
If you fail to comply with the Terms of Use, or the Privacy Policy, or are investigated for misconduct, TTWGROUP may restrict your access. In this case, you will also be legally responsible for this conduct.
TTWGROUP may, in connection with court orders requesting information, share information necessary for investigations or to take measures related to illegal activities, suspected fraud or potential threats against people, assets or systems that support the service or otherwise necessary to comply with legal obligations.
- Jurisdiction
Any disputes or controversies relating to the use of the websites and/or applications, including non-compliance with the Privacy Policy, will be processed by the São Paulo City Court.
You have the right to lodge a complaint with the Brazilian National Data Protection Authority (ANPD), based on article 18, § 1 of the LGPD if you believe that any issue in the Terms of Use has been violated.
- Change of Privacy Policy
The Privacy Policy for the services established here is valid indefinitely, and is subject to change without prior notice. TTWGROUP reserves the right to modify this document at any time, especially to better adapt it to current legislation and adapt it to developments in the services, whether by making new features available or by eliminating or modifying existing ones. Because of this, we recommend checking this page periodically.
Any change or update to the Services Privacy Policy will come into force from the date of its publication on this website and must be fully observed by users.