1Who we are

Twig operates a global network that connects independent freight forwarders. For the purposes of the LGPD and the GDPR, Twig acts as the controller of the personal data described in this Policy, meaning we are responsible for the decisions about how that data is processed.

Twig Logistics Network Serviços LTDA
CNPJ (Brazilian Company ID): 16.788.521/0001-95
Rua da Paisagem, 240, Room 23, Vila da Serra, Nova Lima, MG, 34006-059, Brazil
Phone: +55 31 9594-1917
Data protection contact: privacidade@twignetwork.com
General enquiries: twig@twignetwork.com

2Information we collect

"Personal data" means any information relating to an identified or identifiable person. We collect the following categories:

• Contact and professional data: name, company name, job title, business email, phone number, country and the professional profile information you choose to share with us.
• Membership and event data: company details, documentation and certifications submitted in a membership application, event registration data, and information related to your participation in our conferences.
• Commercial data: records of your interactions with us, including messages, requests, meeting notes and communication preferences.
• Technical and usage data: browser type and version, operating system, referring website, pages and subpages visited, date and time of access, and IP address. This data is recorded in server log files and is evaluated on an aggregated, anonymized basis.
• Advertising and analytics data: identifiers and events generated by cookies and similar technologies that allow us to measure the performance of our campaigns and understand how visitors use our website.

We do not intentionally collect sensitive personal data (such as data revealing health, religion, political opinions or biometric information). Please do not include such information in our forms.

3How we collect it

Information you give us directly

We collect the data you voluntarily submit when you fill in a form on our website, contact us by email, phone or messaging apps, apply for membership, register for an event, or subscribe to our newsletter. If you contact us through a contact form or by email, the personal data you provide is stored so that we can respond to and process your request.

Information from social media and advertising platforms

When you complete a lead form hosted on LinkedIn, Meta or another social media platform in response to a Twig advertisement, that platform transmits to us the information you submitted in the form (typically name, professional email, company, job title and country) so that we can follow up on your request. The platform's own processing of your data is governed by its own privacy policy, and for that processing the platform acts as an independent controller.

Information collected automatically

When you access our website, technical data is collected automatically through cookies, pixels and server logs, as described in section 7. Twig does not use this data to draw conclusions about you as an individual; it is used to deliver our content correctly, improve our website and advertising, keep our systems secure and, where necessary, provide law enforcement with the information required to investigate a cyber-attack.

Information from public and third-party sources

We may collect business contact information that has been made publicly available by you or by third parties, such as a company website or a public professional profile, in order to assess a potential fit with our network.

4Why we use it and legal bases

We only use your personal data for the purposes below, and we limit the data used to what is strictly necessary to achieve each purpose.

• To respond to your request or enquiry and to send you the material or information you asked for. Legal basis: the pre-contractual steps taken at your own request (LGPD art. 7, V; GDPR art. 6(1)(b)).
• To assess membership applications and to enter into and perform our contract with your company, including managing annual fees and renewals. Legal basis: performance of a contract or the pre-contractual steps taken at your request.
• To provide and operate our services and platform, to connect members with other freight forwarders in the network, to verify accounts and activity, to prevent fraud and harmful conduct, and to provide support. Legal basis: performance of a contract and our legitimate interest in operating a secure and reliable network.
• To organize our conferences and events, including registration, rooming, logistics and on-site communication. Legal basis: performance of a contract.
• To send you news, updates, invitations and marketing communications about Twig, its services and its events, where you have given us your professional contact details or already have a business relationship with us. Legal basis: our legitimate interest in direct business-to-business communication with professionals in the freight forwarding sector (LGPD art. 7, IX; GDPR art. 6(1)(f)), balanced against your rights. You can object or opt out at any time, and every email we send includes an unsubscribe link.
• To measure and improve our website, content and advertising, including measuring the results of our campaigns on LinkedIn and other platforms. Legal basis: our legitimate interest in understanding and improving our own performance and, for non-essential cookies and advertising pixels, your consent given through our cookie banner.
• To comply with legal and regulatory obligations and to exercise or defend our rights in legal proceedings. Legal basis: compliance with a legal obligation and the regular exercise of rights.

We do not make decisions about you based solely on automated processing that would produce legal effects or significantly affect your interests.

5Sharing your information

We do not sell your personal information.

We share personal data only as described below:

• Other Twig members: if your company becomes a member, the company profile and business contact details approved by you become visible to other members on our platform, so that they can contact you for business purposes. Members are responsible for their own use of that information, and any deal negotiated between members is their sole responsibility.
• Service providers acting on our behalf: hosting and infrastructure, email and CRM platforms, event and travel suppliers, payment and accounting providers, and analytics and advertising platforms such as LinkedIn and Meta. These providers act as operators (processors) under our instructions and are bound by confidentiality and data protection obligations.
• Professional advisers, such as auditors, lawyers and insurers, where necessary and under a duty of confidentiality.
• Authorities and legal requirements: where disclosure is required by law or by a judicial, administrative or regulatory authority, or is necessary to protect our rights, our users or third parties.
• Corporate transactions: in connection with a merger, acquisition or reorganization, in which case the recipient will remain bound by this Policy.

6International transfers

Twig is headquartered in Brazil and operates a network spanning members and offices in dozens of countries. Some of our service providers are located outside your country of residence, including in the United States and the European Union. As a result, your personal data may be transferred to, stored in and processed in countries whose data protection laws differ from those of your own.

When we transfer personal data internationally, we do so in accordance with the requirements of the LGPD and, where applicable, the GDPR, relying on transfers to countries recognized as providing an adequate level of protection or on contractual safeguards such as standard contractual clauses that require the recipient to protect the data to an equivalent standard.

7Cookies and similar technologies

Cookies are small text files stored on your device by your browser. They allow a website to recognize your browser on a later visit, which makes the site easier to use (for example, by not requiring you to re-enter information at each visit) and allows us to measure how the site performs. We also use similar technologies such as advertising pixels and tags.

We use the following categories of cookies and similar technologies:

• Essential cookies, required for the website to function, to keep your session active and to keep it secure. These cannot be disabled through our website.
• Analytics cookies, which help us understand how visitors find and use our website so that we can improve it.
• Advertising cookies and pixels, including those provided by LinkedIn and Meta, which allow us to measure the results of our campaigns and to show relevant advertising to professionals in our sector.

You can manage non-essential cookies at any time through the consent banner on our website, where available, and you can block or delete cookies at any time through your browser settings. If you disable cookies, some functions of our website may not be fully available.

8How long we keep it

We keep personal data only for as long as necessary to fulfil the purposes described in this Policy, or for as long as required by applicable law and by the rules to which we are subject. When the purpose of the processing ends, the applicable retention period expires, or you validly object to the processing, whichever occurs first, the data is deleted in accordance with legal provisions.

Retention periods vary according to the nature of the data, the reason it was collected and any operational or legal need to retain it. Anonymized data, which can no longer be associated with an identifiable person, may be kept indefinitely for statistical purposes.

Please note that deletion of your data does not restrict our ability to investigate potential violations of our User Agreement or of the law, to comply with a legal obligation, or to respond to a request from a judicial or administrative authority. Content that has already been shared by other members remains under the responsibility of those members.

9Security

Twig implements technical and organizational measures designed to protect personal data against unauthorized access and against accidental or unlawful destruction, loss, alteration, communication or any other improper or unlawful form of processing. Access to personal data is restricted to personnel and providers who need it to perform their role.

No method of transmission or storage over the internet is completely secure, so we cannot guarantee absolute security. In compliance with article 48 of Law No. 13.709/2018, we will notify affected data subjects and the Brazilian National Data Protection Authority (ANPD) of any security incident that may cause significant risk or damage.

10Your rights

Subject to applicable law, you may exercise the following rights in relation to your personal data at any time, free of charge:

• Confirmation and access: confirm whether we process your personal data and obtain access to it.
• Correction: have incomplete, inaccurate or outdated data corrected.
• Anonymization, blocking or deletion of data that is unnecessary or excessive, or that has been processed in breach of the law.
• Deletion of your personal data, except where we are required or permitted to retain it under article 16 of the LGPD or under another applicable legal basis.
• Portability: receive your data, or have it transferred to another service provider, in accordance with the regulations of the supervisory authority and subject to commercial and industrial secrecy.
• Information about sharing: learn which public and private entities your data has been shared with.
• Information about consent: where we do ask for your consent, be informed of the possibility of refusing it and of the consequences of that refusal.
• Objection and opt-out at any time, as described in section 11.
• Objection to processing carried out on the basis of our legitimate interest, and the right to opt out of marketing communications at any time.
• Review of automated decisions that affect your interests, including decisions intended to define your personal, professional, consumer or credit profile.

To exercise any of these rights, contact us at privacidade@twignetwork.com. We may need to confirm your identity before responding, and we will reply within the timeframes established by applicable law. If you are in the European Union or the United Kingdom, you also have the right to lodge a complaint with your local supervisory authority; in Brazil, you may contact the ANPD.

11Objecting and opting out

Most of the processing described in this Policy does not rely on your consent: we process your data to answer a request you made, to perform our contract with your company, or on the basis of our legitimate interest. Because of this, you have the right to object to that processing at any time and to opt out of our communications, free of charge and without giving a reason.

To do so, click the unsubscribe link in any of our emails, or write to privacidade@twignetwork.com. We will stop the relevant processing and record your objection, and we will respond within the timeframe established by applicable law. Where we do rely on your consent, such as for non-essential cookies, you can withdraw it at any time through our cookie banner or your browser settings; withdrawal does not affect the lawfulness of processing carried out before it.

We keep a documented balancing assessment of the legitimate interests described in this Policy and make it available to the competent supervisory authority on request.

If you are a member, please be aware that it may not be possible for us to continue providing our products and services after the deletion of your personal data.

12Minors

Our website, platform and events are directed exclusively at professionals and companies. We do not knowingly collect personal data from children or adolescents. If you believe that a minor has provided us with personal data, please contact us so that we can delete it.

13Links to other websites

Our website and communications may contain links to websites operated by third parties, including member companies, event venues and social media platforms. We have no control over the content or privacy practices of those websites and are not responsible for them. We encourage you to review the privacy policy of any website you visit through one of our links.

14Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, our services or applicable law. The most recent version will always be available on this page, with the date of the last update shown at the top. Where changes are material, we will provide notice through our website or by other appropriate means before they take effect.

15Contact us

For any question about this Policy, about how we handle your personal data, or to exercise your rights, please use the dedicated data protection channel below. Requests received through it are handled by the person appointed by Twig as data protection officer (Encarregado de Dados) under article 41 of the LGPD.