privacy policy

At TWA Brands – We respect your privacy and thank you for the trust you place in us. In this Privacy Policy, we explain for what purposes we may use your data and how we process it.

Who is responsible for the processing of your personal data?

TWA Brands is responsible for the processing of data of its Clients and potential Clients, who browse this website and/or fill in the forms made available by it and with whom they maintain business relations.

For questions related to the processing of your personal data, you may contact the Data Protection Officer through the following means:

TWA Brands GmbH
Hansastrabe 17, 20149 Hamburg
E-mail: tobias.wengeler@twa-brands.com

How do we collect your personal data?

Your personal data will be collected and processed in the following situations:

If you fill in your personal data and submit forms on this website;

If you use a service provided by us or purchase a product from our sales line;
Through indirect collection, we access statistical information relating to the use of the website, in an aggregated and anonymous form;
In the context of work: having for this purpose a staff of employees attached to its organization;
TWA Brands also uses cookies on the website to improve performance and user experience.

"Cookies" are small text files that are stored on your computer or mobile device, through your browser, retaining only generic information related to the user's preferences; They allow access to specific areas of the site and faster and more efficient navigation, eliminating the need to repeatedly enter the same information.

Users of the website by clicking on the cookie banner, with the mention ACCEPT/ACCEPT, continuing to browse the website are accepting, including for future accesses, the introduction of cookies under the terms indicated above. At any time, the user may, through the browser, decide to be notified about the receipt of cookies, as well as block their entry into their system. Removing or blocking cookies on the website may limit access to some areas of the website.

For what purposes and on what grounds may your personal data be used?
Customer Management

The data collected is processed automatically and is intended, within the TWA Brands, for the registration of the Customer file, consequent collection, invoices and future contacts, namely information on ongoing supplies. Under the terms of Regulation 2016/679, the holder has the right to access, rectify and delete the same, by sending a communication to the e-mail address tobias.wengeler@twa-brands.com

Use of the website

As a visitor to the website, it is not necessary to provide any personal data to use the TWA Brands website.

Users' personal data are collected only when they subscribe to any of the available features, which are essential for them to provide the information, or when they fill out some type of form available, such as: request for information about advertised products, participation in events.

Marketing/Communication

Your data will be collected and used for Marketing purposes (newsletter communication, events, services, sale of products and other information that is considered relevant), under the exact terms selected by you in the Preferences Form on this page. This data processing will only be carried out with your consent. If you consent, you will receive marketing communications via email or SMS. You may object to this data processing at any time. Your data will be kept for this purpose until you exercise your right to object.

Recruitment

During the personnel selection and recruitment process, TWA Brands collects and processes the personal data of the respective candidates for the purpose of entering into a contract.

In the case of spontaneous applications, they are subject to analysis, and TWA Brands requests express consent to keep them on file for a certain period – which, in compliance with the recommendations of the National Data Protection Commission, may not exceed twelve (12) months – in the expectation of a future professional opportunity.

On what basis may we process your personal data?

We process your personal data in the following cases:

Assent

When you have given your express consent – in writing, orally or through the validation of an option – and prior and if such consent is free, informed, specific and unambiguous.

or

Contract execution and pre-contractual procedures

When the processing of personal data is necessary for the conclusion, execution and management of the contract entered into or in the process of entering into with TWA Brands

or

Compliance with a legal obligation

When the processing of personal data is necessary to comply with a legal obligation to which TWA Brands is subject.

or

Legitimate Interest

When the processing of personal data, restricted to minimum data, corresponds to a legitimate interest of the controller, for example, the processing of data indispensable to the improvement of the quality of services.

What are the terms for processing and storing personal data?

TWA Brands processes and stores your personal data in accordance with the purposes for which they are processed.

There are cases in which the law requires the processing and retention of data for a minimum period, namely for 10 (ten) years, in the case of data necessary for information to the Tax Authority for accounting or tax purposes.

Where there is no specific legal obligation, the data will be processed only for the period necessary for the fulfilment of the purposes for which it was collected and preserved.

Transmission of personal data – How does it work?

Your personal data is processed exclusively by TWA Brands which may use subcontracted platforms for its own management, such as e-mail marketing platforms. In these cases, it is incumbent on TWA Brands to take the necessary contractual measures to ensure that the subcontractors respect and protect the personal data of the data subject, which are in their custody and responsibility.

What rights are guaranteed to the holders of Personal Data?

At any time, you can:

Request access to the information we hold about you: as a data subject, you have the right to obtain confirmation as to whether or not the data concerning you is being processed and, where applicable, to access your personal data and to access the information provided for by law, in this matter.

Request the rectification of the information if it is inaccurate or incomplete: as the holder of the personal data, you have the right to have TWA Brands, without undue delay, rectify inaccurate or incomplete data concerning you

Request the deletion of your personal data: as the holder of your personal data, you have the right to request the deletion of your data from TWA Brands, and the latter has the obligation to delete the personal data, without undue delay, when one of the following reasons applies, in particular:

  • (a) the personal data are no longer necessary for the purpose for which they were collected or processed;
  • b) You have withdrawn your consent to the processing of data (in cases where the processing is based on consent) and there is no other ground for such processing;
  • c) Objection to the processing and lack of overriding legitimate interests justifying the processing.

Request the restriction of the processing of your personal data: as a data subject, you have the right to request from TWA Brands the restriction of the processing of your data if one of the following situations applies:

  • a) Contest the accuracy of the personal data, for a period that allows TWA Brands to verify its accuracy;
  • b) The data processing is lawful and the data subject opposes the erasure of the personal data and requests, in return, the restriction of its use;
  • c) TWA Brands no longer needs the personal data for processing purposes, but such data are required by the data subject for the purposes of declaring, exercising or defending a right in a legal proceeding;
  • d) If you have objected to the processing, until it is established that the legitimate grounds of the controller prevail over those of the data subject.

Object to the processing of your personal data: in cases where the data processing is carried out for the purposes of the legitimate interests pursued by TWA Brands.

If the processing depends on your consent, you have the right to withdraw it: if consent is legally necessary for the processing of personal data, the data subject has the right to withdraw consent at any time, although this right does not compromise the lawfulness of the processing carried out on the basis of the consent previously given, nor the further processing of the same data, based on another legal basis, such as the performance of the contract or the legal obligation to which it is subject.

Complain to the supervisory authority – National Commission for Data Protection;

Know if there is a data breach/security incident, as below.

If you wish to exercise any of your rights, you must contact us, in writing, by e-mail to tobias.wengeler@twa-brands.com or by letter to the address indicated below – Hansastrabe 17, 20149 Hamburg

Security of Personal Data

TWA Brands uses technical and organizational measures to protect the security and confidentiality of Personal Data in accordance with the General Data Protection Regulation.

These measures will be reviewed whenever there are new legal requirements and there is a need for technological developments.

In the event of a breach of security that causes, accidentally or unlawfully, the destruction, loss, alteration, disclosure or unauthorised access to personal data, TWA Brands will notify the competent authority of the occurrence within the legal period, as well as to the data subject himself.

Complaint to the Supervisory Authority

In the event that you are not satisfied with the way we process your personal data, you have the right to lodge a complaint with the National Data Protection Commission (CNPD);Rua de São Bento, nº. 148 – 3rd; 1200- 821 Lisbon; or by e-mail: geral@cnpd.pt