1 Introduction
Seatrium Singmarine Brasil Ltda (hereinafter "Seatrium Singmarine Brasil", "we", "us", or "our"), registered under CNPJ 12.464.792/0001-34 and headquartered at Rua Prefeito Manoel Evaldo Muller, 3388, Volta Grande, Navegantes-SC, Brazil, operates the website accessible at seatrium.site (the "Site").
We take privacy seriously. This Privacy Policy describes how we collect, use, store, and protect personal data obtained through our Site, as well as the rights that individuals have regarding that data. It has been prepared in accordance with Brazil's Lei Geral de Proteção de Dados Pessoais (LGPD — Law No. 13,709/2018) and, where applicable to users located in the European Economic Area or the United Kingdom, the General Data Protection Regulation (GDPR — Regulation (EU) 2016/679).
By visiting our Site, you acknowledge that you have read and understood this policy. If you do not agree with any part of it, please discontinue your use of the Site. This policy applies solely to information collected through this Site and does not govern data processed in the context of employment contracts, supplier agreements, or other bilateral commercial relationships that are subject to their own documentation.
Who is the data controller? For the purposes of LGPD and GDPR, the data controller is Seatrium Singmarine Brasil Ltda, CNPJ 12.464.792/0001-34, Rua Prefeito Manoel Evaldo Muller, 3388, Volta Grande, Navegantes-SC, Brazil. Contact details are listed in Section 11 of this policy.
2 Information We Collect
We collect the minimum amount of information necessary to respond to your inquiries, maintain a functioning website, and improve our communications. The categories of information we may collect are described below.
Information you provide directly
When you use the contact details published on our Site to send us an email or reach us by telephone, you may voluntarily share personal information such as your full name, company name, professional title, email address, phone number, and the content of your message. We use this information solely to respond to your inquiry and, with your consent, to follow up regarding our services.
Information collected automatically
When you visit our Site, our servers and third-party analytics services automatically record certain technical data. This may include:
- Your Internet Protocol (IP) address, which may indicate your approximate geographic location at a city or country level;
- The type, version, and language settings of your web browser;
- The operating system and device type (desktop, tablet, mobile);
- The URL of the webpage you visited immediately before arriving at our Site (referrer URL);
- The pages and sections of our Site you viewed, and the duration of each visit;
- Date and time stamps for each page request;
- Interaction data such as clicks, scroll depth, and navigation paths.
This technical data is primarily aggregated and anonymised for analytics purposes. Where it constitutes personal data under applicable law (for example, where an IP address can be linked to an identifiable individual), we treat it accordingly.
Cookie-derived data
We and our third-party service providers place cookies and similar tracking technologies on your device when you visit the Site. Cookie-derived information may include session identifiers, browsing preferences, and marketing attribution signals. Please see Section 4 of this policy for full details of the cookies we use, how to manage them, and the legal basis for their deployment.
3 How We Use Your Information
We use personal data only for the purposes for which it was collected, and only where we have a valid legal basis to do so. The table below sets out our principal processing purposes alongside the corresponding legal basis under LGPD and GDPR.
Responding to enquiries and business communications
When you contact us by email or telephone, we use the information you provide to respond to your message accurately and in a timely manner. The legal basis is the performance of pre-contractual steps at your request (LGPD Art. 7(V); GDPR Art. 6(1)(b)) or our legitimate interest in conducting business (LGPD Art. 7(IX); GDPR Art. 6(1)(f)).
Operating and improving the Site
We process technical and analytics data to monitor the performance and security of our Site, diagnose errors, and make informed decisions about content and user-experience improvements. The legal basis is our legitimate interest in maintaining a professional, secure, and effective online presence (LGPD Art. 7(IX); GDPR Art. 6(1)(f)).
Advertising and measurement
Where you have consented to cookies for advertising purposes, we may use data collected through those cookies to measure the effectiveness of Google Ads campaigns that direct visitors to our Site. We do not use this data to build individual profiles or for re-targeting beyond what is inherent in the ad-platform features we have enabled. The legal basis is consent (LGPD Art. 7(I); GDPR Art. 6(1)(a)).
Legal compliance and dispute resolution
In certain circumstances, we may be required to process or disclose personal data to comply with a legal obligation, respond to a judicial or regulatory request, or exercise or defend our legal rights. The legal basis is compliance with a legal obligation (LGPD Art. 7(II); GDPR Art. 6(1)(c)) or legitimate interests (GDPR Art. 6(1)(f)).
No automated decision-making: We do not subject any individual to automated decision-making — including profiling — that produces legal or similarly significant effects. All decisions relating to business relationships are made by human members of our team.
4 Cookies & Tracking Technologies
Cookies are small text files placed on your device by a website you visit. They serve a variety of functions, from keeping the site working correctly to helping us understand how visitors interact with our content. We use the following categories of cookies:
Strictly necessary cookies
These cookies are essential for the Site to function correctly — for example, to remember your cookie consent preferences or maintain session integrity. They cannot be disabled without breaking core Site features. No consent is required for strictly necessary cookies because they are deployed on the basis of our legitimate interest and technical necessity.
Analytics cookies
We use Google Analytics to collect aggregated, anonymised data about how visitors navigate the Site — which pages are most visited, how long users spend on each section, and how they arrive at our Site. Google Analytics uses first-party cookies (such as _ga and _gid) to distinguish unique visitors and sessions. We have configured IP anonymisation so that full IP addresses are never stored by Google Analytics. This data helps us improve our content and allocate resources effectively. These cookies are deployed only with your consent.
Advertising and measurement cookies
If you arrive at our Site via a Google Ads advertisement, Google may place a cookie (such as _gcl_au) on your device to record the ad that directed you here, so that we can measure conversion events and the return on our advertising investment. We do not use these signals to serve retargeted display advertising to individual users through our own operations, though the Google Ads platform may do so in accordance with Google's own privacy policies. These cookies are deployed only with your consent.
Managing your cookie preferences
When you first visit our Site, a cookie consent banner will request your permission before any non-essential cookies are placed. You may withdraw or change your consent at any time by clearing the cookies stored in your browser and revisiting our Site, at which point the consent banner will be presented again.
You can also manage or delete cookies through your browser settings. The following links provide instructions for the most commonly used browsers: Chrome, Firefox, Safari, Edge, and Opera all publish cookie management guidance in their respective help centres. Note that disabling analytics or advertising cookies does not affect the core informational content of this Site.
To opt out of Google Analytics tracking across all sites that use it, you may install the Google Analytics Opt-out Browser Add-on, available at tools.google.com/dlpage/gaoptout. For Google Ads personalisation, you can manage your preferences via Google's Ad Settings at adssettings.google.com.
5 Sharing With Third Parties
We do not sell, rent, trade, or otherwise commercially exploit personal data. We share data only in the limited circumstances described here:
Service providers and data processors
We engage trusted third-party companies to help us operate and improve the Site. These include web hosting infrastructure providers, cloud storage services, and analytics platforms (Google LLC, for Google Analytics and Google Ads). These providers act as data processors under our instruction and are contractually prohibited from using your data for any purpose beyond the service they provide to us. We require all processors to implement appropriate technical and organisational security measures.
Our corporate group
Seatrium Singmarine Brasil Ltda is a subsidiary of the Seatrium group of companies. We may share data within the group where necessary to coordinate business enquiries or provide the services you have requested. Intra-group transfers are governed by internal data-sharing agreements consistent with applicable law.
International transfers
Some of our third-party service providers, including Google LLC, are based in the United States and other jurisdictions outside Brazil and the EEA. When we transfer personal data internationally, we ensure that appropriate safeguards are in place — such as Standard Contractual Clauses approved by the European Commission, or transfers to jurisdictions recognised as providing an adequate level of protection by Brazil's Autoridade Nacional de Proteção de Dados (ANPD).
Legal disclosures
We may disclose personal data if required to do so by law, court order, or governmental authority, or where we believe in good faith that disclosure is necessary to protect our legal rights, prevent fraud, or ensure the safety of our employees or third parties.
Business transfers
In the event of a merger, acquisition, restructuring, or sale of all or part of our business, personal data held by us may be transferred to the acquiring entity. We would notify affected individuals and ensure that any such transfer complies with applicable privacy law.
6 Data Retention
We keep personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by law. Our general retention guidelines are as follows:
- Contact and enquiry records: Correspondence and related personal data are retained for up to 5 years from the date of last communication, unless a pre-contractual or contractual relationship develops, in which case records are retained in accordance with our commercial document retention schedule (up to 10 years, in line with Brazilian civil and tax law requirements).
- Analytics data: Google Analytics data is retained for 14 months at the property level, after which it is automatically aggregated or deleted. We do not export identifiable analytics records to our own systems.
- Advertising measurement data: Google Ads conversion data is retained for 90 days by default, consistent with standard campaign attribution windows.
- Cookie consent logs: Records of your consent to or refusal of cookies are retained for 12 months, to align with the period during which consent remains valid before we will ask again.
- Server access logs: Web server logs containing IP addresses and request metadata are retained for a maximum of 90 days for security monitoring purposes, then purged.
Where data is no longer needed, we securely delete or irreversibly anonymise it. Anonymised data (which cannot be linked to any identifiable individual) may be retained indefinitely for statistical purposes.
7 Data Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security measures include:
- Transport Layer Security (TLS 1.2 or higher) encryption for all data in transit between your browser and our web servers;
- Access controls that restrict personal data to employees and contractors who require it to perform their duties, operating on a need-to-know basis;
- Regular review of access permissions and removal of access rights upon role changes or departure;
- Use of reputable hosting and cloud infrastructure providers that maintain ISO 27001-aligned or equivalent security certifications;
- Vulnerability monitoring and periodic security assessments of the Site and its dependencies.
Despite these measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security, and we encourage you to communicate sensitive business information through direct, verified channels rather than unsolicited email.
In the event of a personal data breach that is likely to result in a high risk to the rights and freedoms of individuals, we will notify the affected individuals and the relevant supervisory authority (Brazil's ANPD, and/or the competent EEA authority) within the timeframes required by applicable law — 72 hours under GDPR, and within a reasonable period under LGPD.
8 Your Rights
Under LGPD and GDPR, you have substantive rights over your personal data. These rights are not absolute — they are subject to certain legal limitations — but we are committed to honouring them in full where they apply. The rights you hold are:
Right of Access
You may request confirmation of whether we hold personal data about you, and obtain a copy of that data together with information about how it is processed.
Right of Correction
If personal data we hold about you is inaccurate, incomplete, or out of date, you may ask us to correct or supplement it without undue delay.
Right of Deletion (Erasure)
You may request that we delete your personal data where it is no longer needed for the purpose for which it was collected, or where you withdraw consent and no other lawful basis applies.
Right to Object
Where we process data on the basis of legitimate interests, you have the right to object. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
Right to Withdraw Consent
Where processing is based on your consent — such as for analytics or advertising cookies — you may withdraw that consent at any time, without affecting the lawfulness of processing carried out before withdrawal.
Right to Data Portability
You may request that we provide personal data you have given us in a structured, commonly used, machine-readable format, so that you can transmit it to another controller.
Right to Restriction
In certain circumstances — for example, while the accuracy of data is contested, or where an objection is pending — you may ask us to restrict the processing of your data.
Right to Lodge a Complaint
You have the right to lodge a complaint with Brazil's Autoridade Nacional de Proteção de Dados (ANPD) or, for EEA residents, with your local data protection supervisory authority.
How to exercise your rights
To exercise any of the rights listed above, please contact our Data Protection point of contact by email at contato@seatrium.site, with the subject line "Privacy Rights Request". Please include your full name and, if possible, a description of the personal data to which your request relates. We will acknowledge your request within 5 business days and respond substantively within 15 business days (extendable by a further 15 days for complex or numerous requests, with prior notice to you). We will not charge a fee for handling reasonable rights requests.
We may need to verify your identity before processing a request, to protect the privacy of others and prevent fraudulent access to personal data. We will ask you to provide information sufficient to confirm your identity without requiring disproportionate documentation.
9 Children's Privacy
Our Site is a corporate information resource directed exclusively at professionals, businesses, and adults with a legitimate interest in maritime and offshore engineering services. It is not intended for, and does not knowingly collect personal data from, children under the age of 18, or from individuals under any higher age threshold defined by applicable law in their jurisdiction.
If we become aware that we have inadvertently collected personal data from a minor without appropriate parental or guardian consent, we will take immediate steps to delete that information from our records. If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us without delay at contato@seatrium.site.
10 Changes to This Policy
We review this Privacy Policy periodically and update it whenever our practices change, new legal obligations arise, or we introduce new data-processing activities. The "Last updated" date at the top of this page reflects the date of the most recent revision.
When we make material changes — such as processing new categories of personal data, changing our retention periods, or introducing new third-party processors — we will take reasonable steps to notify you. This may include displaying a prominent notice on our Site's homepage or updating the cookie consent banner to draw attention to the revised policy.
We encourage you to revisit this page periodically. Your continued use of the Site following the posting of changes constitutes your acknowledgement of those changes, subject to any consent obligations that may arise under applicable law.
Archived versions of this policy are available on request by emailing contato@seatrium.site.
11 Contact & Data Protection Point of Contact
If you have any questions, concerns, or requests relating to this Privacy Policy or the way we handle your personal data, we encourage you to contact us directly. We are committed to resolving any issues promptly and transparently.
