ETSP Executive Transfer SP values your privacy and takes steps to protect your personal data. This Privacy Policy explains how we collect, use, store, and share information when you visit our website, contact us, or use our executive transportation services. By using our website and/or contacting us through our channels, you agree to the practices described in this Policy.

1) Who we are (Data Controller)
ETSP Executive Transfer SP is responsible for the processing of personal data described in this Policy (“Controller”).
Contact (WhatsApp): +55 (19) 99453-2889

2) What data we may collect
We may collect personal data you provide and data generated through website usage:

2.1. Data you provide (examples):
• Full name
• Phone/WhatsApp number
• Email address (if you send it)
• Trip details for quoting and service execution: origin, destination, date/time, number of passengers, preferences and notes
• Information needed for receipts and support (when applicable)

2.2. Data collected automatically on the website:
• IP address and technical device/browser data
• Pages visited, time on site, clicks, traffic source
• Cookies and similar technologies (see “Cookies” section)

2.3. Sensitive data
We do not request sensitive data (such as health data, religion, biometrics, etc.). If you share it voluntarily, please avoid providing such information.

3) How we use your data (purposes)
We use personal data to:
• Respond to inquiries and quote requests
• Plan and provide the transportation service (logistics, timing, route, bilingual support when needed)
• Send service-related communications (confirmations, changes, important notices)
• Improve the website and user experience (navigation analytics, performance, security)
• Comply with legal and regulatory obligations, when applicable
• Prevent fraud and maintain safety across our services and channels

4) Legal basis
We process personal data under applicable legal bases, such as:
• Contract performance and pre-contract steps (e.g., quotes and scheduling)
• Legitimate interests (e.g., security, website improvements, fraud prevention)
• Legal/regulatory compliance, when required
• Consent, when necessary (e.g., certain cookies and communications)

5) Data sharing
We may share personal data only when necessary for:
• Service delivery (e.g., operational communication and logistics)
• Technology providers (hosting, forms, analytics, and website security tools)
• Legal compliance or lawful requests by authorities
We do not sell personal data.

6) Cookies and similar technologies
Cookies are small files that help the website function and improve your experience.
We may use:
• Essential cookies: required for functionality and security
• Performance/analytics cookies: help understand how the site is used (in aggregated
form)
• Marketing cookies (if applicable): to measure campaigns and ads
You can manage cookies through your browser settings (block, delete, or limit). Disabling
cookies may affect certain website features.

7) Data retention
We keep personal data only as long as needed to:
• Handle your request and provide the service
• Meet legal obligations and protect rights (e.g., retention requirements)
• Maintain security and anti-fraud records
When no longer needed, data is deleted or anonymized when possible.

8) Information security
We apply technical and organizational measures to protect personal data against unauthorized access, misuse, loss, or alteration. However, no system is completely secure, so we recommend protecting your devices and avoiding sharing codes/passwords.

9) Your rights
Depending on applicable law, you may request:
• Confirmation of processing and access to your data
• Correction of inaccurate or outdated data
• Deletion, anonymization, or restriction (when applicable)
• Data portability (when applicable)
• Information about data sharing
• Withdrawal of consent (when consent is the legal basis)
To exercise your rights: contact us on WhatsApp +55 (19) 99453-2889.

10) Third-party links
Our website may include links to third-party services (e.g., maps, social media). We are not responsible for their policies and practices. Please review their privacy policies.

11) Children’s privacy
Our services are intended for the general public and businesses. We do not knowingly collect children’s data without a parent/guardian. If you believe a minor’s data was provided improperly, please contact us so we can review and address the situation.

12) Policy updates
We may update this Policy to reflect improvements and legal/operational changes. The current version will always be available on the website with the “Last updated” date. Contact: WhatsApp +55 (19) 99453-2889