Data Processing Policy

Shackleton's Way Agente de Naves Limitada (Shackleton's Way Ship Agents & Suppliers)
In accordance with Law 19,628 on the Protection of Private Life (Chile)

1. Introduction

This Privacy Policy sets out how we collect, use, share and protect the personal and biometric data of visitors, crews, clients and other stakeholders of Shackleton's Way, including passport and identity-document information, in accordance with Law No. 19,628 on the Protection of Private Life of the Republic of Chile.

Shackleton's Way is a ship agency and Antarctic logistics company operating from Punta Arenas, Chile. We provide maritime, logistics, aviation and Antarctic operational support to vessels, expeditions, crews and organisations operating in the Magallanes Region and Antarctica.

2. Data controller

The collection and processing of your personal data is the responsibility of:

Legal name of the company: Shackleton's Way Agente de Naves Limitada
Tax ID (RUT): 76.631.726-K
Main operational address (Punta Arenas): Pedro Sarmiento de Gamboa 846, Punta Arenas, Magallanes Region, Chile
Contact email: info@sway.cl
Data Protection Officer (DPO): Alejandro Jiménez (contact: info@sway.cl)

3. Personal and sensitive data we collect

We collect the following types of personal data in the course of our ship agency and Antarctic logistics operations:

Sensitive data (identification documents):

• Passport numbers
• National identity card numbers
• Date of birth
• Nationality of the holder

Crew and personnel identification data: full name, shipping company, position, email address, telephone number and address.

Port operations data: vessel information, arrival and departure dates, port of call, agent details and cargo manifests.

Browsing and web access data: IP address, browser type, operating system, pages visited and time of access.

Contact and enquiry data: information provided through service request forms, operational enquiries and customer service.

3.1. Key information about sensitive data

Under Law 19,628, the processing of sensitive data (such as passport numbers and identity-document data) requires:

Explicit, prior consent. You must give informed, specific and unambiguous consent before we collect any passport or identity-document data. This consent must be freely given and granted specifically for the operational purposes described in this policy.

A clear justification of necessity. We collect passports and identity documents in order to:

• Comply with port and customs authority requirements
• Verify crew identity for maritime and port operations
• Manage the port call (arrival and entry of vessels and crew into port)
• Coordinate immigration and international customs procedures
• Comply with international maritime and Antarctic regulations

Proportionality. We only collect the passport data strictly necessary to meet the operational and regulatory requirements listed above. We will not request information that is not essential to the operation.

4. How we collect data

Personal data, including passport data, is collected in the following ways:

• Directly from masters and shipping agents: through operational forms and service requests.
• Vessel documentation: information provided in manifests and official port-call documentation.
• Immigration and customs systems: data shared by the competent authorities for coordination purposes.
• Website: voluntary contact through service request forms.

5. Purposes of processing

We use your personal data to:

• Manage port operations and port calls
• Coordinate with customs and immigration authorities
• Verify the identity of crews and authorised personnel
• Comply with maritime legal and regulatory obligations
• Coordinate ship agency services
• Support Antarctic logistics and expeditions (where applicable)
• Respond to operational requests and additional service enquiries
• Audit operations and ensure compliance with maritime industry standards

6. Legal basis

The processing of your personal data, and in particular of sensitive data such as passports, is based on:

• Law 19,628 on the Protection of Private Life (Chile)
• The explicit consent of the data subject (a specific requirement for sensitive data)
• Compliance with legal port and customs obligations
• International maritime regulations (IMO, SOLAS, etc.)
• The performance of maritime and logistics service contracts

7. Technology infrastructure and use of artificial intelligence

7.1. Private servers and data sovereignty

Shackleton's Way operates its technology infrastructure on private servers located in Santiago, Chile. This ensures:

• Data sovereignty: all data remains within Chilean territory.
• Full control: our own infrastructure, with no dependence on external cloud providers.
• Local compliance: adherence to Chilean data protection laws.

7.2. Use of artificial intelligence

Shackleton's Way uses AI systems to analyse operational data on private servers. Importantly, we do not analyse passport data with artificial intelligence. Passport numbers and identity-document data are:

• Removed from requests before any information is sent to an AI system
• Never processed by AI or machine-learning models
• Kept completely separate from any automated inference

7.3. Daily deletion of AI data

Data processed by AI for operational analysis works under the following model:

• It is not stored on the AI servers
• It is processed in memory only during the active session
• It is discarded immediately after the inference is completed
• It is never used to train models
• It is retained only in separate systems for port-call management purposes

8. Cookies and tracking technologies

Our website uses cookies and similar technologies to:

• Remember browsing preferences and settings
• Analyse site traffic and usage patterns
• Improve the functionality and security of the site
• Facilitate communication between visitors and our operations team

You can control cookies through your browser settings.

9. Sharing and transfer of data

Your personal data may be shared only in the following cases:

• Customs and immigration authorities: when required to process the port call.
• Port authorities: for mandatory port management.
• Shipping companies and agents: for the operational coordination of the vessel.
• Certified service providers: under confidentiality agreements (hosting, email).
• Third parties with explicit consent: when you specifically authorise it.

Important regarding sensitive data: passport data will not be shared with any additional third parties without your explicit and specific consent. All sharing is limited to the competent authorities and direct operational needs.

10. Security and protection of sensitive data

We implement reinforced technical and organisational measures to protect your personal data, and in particular passport data, against unauthorised access; alteration, loss or destruction; and unlawful processing.

Security measures in place:

• 256-bit SSL/TLS encryption of data in transit
• Encrypted storage of sensitive data on private servers
• Firewalls and intrusion detection systems
• Role-based access control (RBAC): authorised personnel only
• Secure and irreversible deletion of data in line with retention policies
• Physical and logical separation of data by sensitivity level
• Regular security audits of the infrastructure
• Continuous monitoring of unauthorised access attempts
• Ongoing staff training on data protection
• Logging of all access to sensitive data

11. Rights of data subjects

Under Law 19,628, you have the following rights:

• Right of access: to know what personal data we hold and how it is used.
• Right of rectification: to correct inaccurate or incomplete data.
• Right to object: to object to the processing of your data at any time.
• Right to erasure: to request the deletion of your data in certain circumstances.
• Right to portability: to receive your data in a structured, readable format.

Additional rights regarding sensitive data:

• The right to withdraw your consent at any time
• The right to request the immediate deletion of passport data
• The right to detailed information on how your identity-document data is stored and used

To exercise these rights, contact us at info@sway.cl. We will respond to every request within a maximum of 15 business days from receipt, in accordance with Chilean law.

12. Retention and deletion

Personal data will be kept for as long as necessary to fulfil the purposes set out above.

Passport data: retained for a maximum of one (1) year from the completion of the port call or service, after which it is securely deleted, unless a longer period is required by law or by the competent authorities.

Data processed by AI: deleted daily from AI systems; not retained on analysis servers; kept only in operational systems for port-call management.

After the retention period, all data will be deleted securely and irreversibly using secure destruction techniques, unless a legal obligation requires a longer retention period.

13. Changes to this policy

We reserve the right to update this Privacy Policy at any time. Significant changes, especially those affecting the processing of sensitive data, will be notified by email or by a prominent notice on our website.

14. Contact and exercise of rights

If you have any questions or concerns, or wish to exercise your data protection rights, please contact us:

Email: info@sway.cl
Head office (Punta Arenas): Pedro Sarmiento de Gamboa 846, Punta Arenas, Magallanes Region, Chile
Data Protection Officer: Alejandro Jiménez (contact: info@sway.cl)

If you believe your rights have been infringed, you may also lodge a complaint with the Personal Data Protection Agency (Agencia de Protección de Datos Personales), which, from December 2026 and under Law 21,719, replaces the Council for Transparency (Consejo para la Transparencia) as the competent authority.

15. Regulatory compliance

Shackleton's Way is committed to complying with:

• Law 19,628 on the Protection of Private Life (Chile)
• All data protection laws in force in Chile
• International maritime regulations (IMO, SOLAS)
• International information security standards
• Chilean customs and immigration regulations

16. Effective date

This Privacy Policy is effective from 4 October 2026.

Informed consent

By accessing our website and providing personal data, including passport numbers, you confirm that you:

• Have read and understood this Privacy Policy in full
• Understand that your data will be processed in accordance with Law 19,628
• Voluntarily consent to the processing of your personal data
• For sensitive data, give your explicit consent to its collection and use in accordance with this policy

Thank you for your trust. This Privacy Policy is designed to protect your rights under current Chilean legislation and international data security standards.

Last updated: 4 October 2026