Privacy Policy
The NEW MAX aims to provide an excellent experience and security for users of its website, and with this in mind, it applies technical and administrative measures, committing itself to the proper handling of personal data provided by data subjects while browsing the website.
We are a company in compliance with the General Data Protection Law and this Privacy Policy aims to inform users of the website about the processing of personal data provided on this website, whether by us or by our partners, also setting out the legal basis for each purpose of processing carried out.
Therefore, we have that this Privacy Policy covers all personal data processing operations that occur on the NEW MAX website and on the WhatsApp of Commercial Service, which is why it applies to users of the website and chatbot.
Please read the entire content of this Privacy Policy before accessing the pages or providing us with any personal data.
To learn more about the practices of NEW MAX regarding personal data, please access the Personal Data Management and Protection Policy.
What data is collected on our website?
When you access our web pages, additional personal information such as your name, email address, company, phone number, city, and state will be collected if you voluntarily provide it, for example, by filling out a contact form for aProduct Quote" or "Supplier Registration" as part of a registration.
On our WhatsApp Customer Service , we will collect your name and company name to open orders.
Also, in the "Work with Us," we will collect your name, email address, phone number, area of interest, city, state, and your resume, and this data will be provided to NEW MAXwith your consent and will be used to support your registration in our talent bank.
We will also use your name and email address when you subscribe to our newsletter.
We also use unique identifier cookies to provide users with a personalized and secure experience, enabling the NEW MAX to access user preferences, browser characteristics, operating system used, IP address (with date and time), information about clicks, pages accessed on our website, or any search terms entered on the site or in reference to it, which will be better explained in the topic on cookies.
As a rule, we do not collect sensitive data on our channels; however, in the "Work with Us," some sensitive data may be collected as part of the registration process, but only if the user chooses to provide it in their resume file.
We will collect sensitive data on our channels when strictly necessary to comply with a legal obligation, exercise a right, or with your consent.
Such information may be stored in third-party databases, including abroad, provided that they respect the privacy and data protection of users at a level consistent with that offered by Brazilian law and this Privacy Policy, and offer adequate security conditions for the storage and processing of such data.
Who is the Data Controller?
A NEW MAX INDUSTRIAL LTDA, a private legal entity registered with the CNPJ under number 67.534.560/0001-05, headquartered at Rua do Marceneiro, 179 – Jardim Werner Plaas, Americana – SP, CEP 13.478-722, is the controller of the Personal Data processed for the purposes described in this Privacy Policy. For the purposes of applicable data protection legislation, the controller is the entity responsible for decisions regarding the processing of personal data.
Personal data processed by NEW MAX may be shared with the Solina Group Holding, an investment company and co-controller of personal data, headquartered in France.
What is the purpose of processing the collected data?
The NEW MAX collects and processes your personal data for the following purposes:
- To process and respond to your requests or to contact you in order to respond to your questions and/or requests through the customer service channels "Product Quote," "Supplier Registration," "Sales," "Customer Service" and "WhatsApp Commercial Service";
- For sending newsletters/direct marketing;
- For statistical studies and marketing and market strategy studies; and
- To inform you and manage your registration and/or subscription in response to the request made on the "Work with Us" page.
The NEW MAX will always process your personal data in accordance with the legal grounds for processing provided for in data protection legislation.
When interacting with the links "Product Quote" or "Supplier Registration," processing will occur based on preliminary activities related to a possible contract with NEW MAX based on your request via the form. As for interactions on the “Sales” and “WhatsApp Commercial Service," personal data will be processed for the execution of your commercial contract.
When contacting customer service,Customer Service”, the data will be processed by NEW MAX based on the execution of your commercial contract, as well as based on the legitimate interest of NEW MAX in better serving its Customers.
The channel "Work with Us" channel and possible subscription to our "newsletter," processing will be based on your consent. For the selection process, if you are approved in the selection process, the data will be processed to comply with legal obligations, as well as to execute the contract or to carry out preliminary procedures related to the contract to which the data subject is a party, at the request of the data subject.
In summary, the Personal Data collected is used by NEW MAX for the purposes and their respective legal bases, as described in the table below:
Collection channel | Purpose of processing | Legal basis for data processing |
Process and respond to your requests or contact you in order to answer your questions and/or requests | Preliminary activities prior to the contract at the request of the holder | |
Identification, classification, and follow-up on your requests, recording of commercial orders, as well as statistical studies and market strategies. | Preliminary activities prior to the contract at the request of the holder | |
Registration – newsletter | Identification and sending of newsletters/direct marketing | Consent |
WhatsApp for Customer Service | Process and respond to your requests or contact you in order to answer your questions and/or requests | Contract Execution |
Process and respond to your requests or contact you in order to answer your questions and/or requests | Contract Performance and Legitimate Interest | |
Inform and manage your registration and/or subscription in response to the request made | Consent | |
Cookies on the website | Statistical studies and marketing and market strategy studies | Consent |
Sharing with third parties may occur for the purposes listed above, or if necessary for: i) Compliance with legal, regulatory, or judicial determinations; ii) Investigation of possible violations of website use; iii) Protection of user rights; iv) Investigations supported by the ANPD.
Legitimate interest of NEW MAX
We will use this legal basis when there is no less intrusive way to process your personal data and always respecting the legitimate expectations of the user and fundamental rights and freedoms. You may object to the processing at any time, as described in the section "Rights of the Data Subject."
The processing of the data subject's data in the customer service channel "SAC" customer service channel will be based on legitimate interest.
Storage Time
Users' Personal Data is processed and stored in an integral and authentic manner, in accordance with Brazilian law, in a database with restricted access.
We will keep your personal data stored for as long as the purpose persists or as determined by law.
In the event of account cancellation or deletion request by the user, the data provided will be deleted using secure disposal techniques, or will be subject to anonymization, in accordance with the law.
The NEW MAX reserves the right to retain the data obtained for the legal periods to ensure the regular exercise of its rights or the rights of third parties, observing at least the period of five (5) years provided for in Article 17 of the Consumer Protection Code and Article 206, §5, I, of the Civil Code, as well as the period of six (6) months provided for in Article 15 of Law No. 12,965/2014.
Furthermore, in order to meet the purposes of processing, the following deadlines were assigned to each channel:
Collection channel | Retention Period | Basis |
Up to 1 year | Term defined by the company as relevant to fulfill the purpose of processing, as well as in compliance with the retention period for providers provided for by the Brazilian Civil Rights Framework for the Internet (Law No. 12,965/2014). | |
Up to 1 year | Term defined by the company as relevant to fulfill the purpose of processing, as well as in compliance with the retention period for providers provided for by the Brazilian Civil Rights Framework for the Internet (Law No. 12,965/2014). | |
Registration – newsletter | Until deregistration by the holder | As determined by Article 18 of the LGPD. |
WhatsApp for Customer Service | Up to 10 years | The data is retained for up to 10 years, due to the statute of limitations for civil liability imposed in contracts – Article 205, CC. |
Undetermined | The data is kept indefinitely, given the need to assess repeat offenses for the same Customer. | |
As long as consent exists or up to 2 years, whichever comes first | As determined by Article 18 of the LGPD and the statute of limitations for labor relations – Article 11 of the CLT in conjunction with Article 7, XXIX, of the CF. | |
Cookies on the website | As long as consent exists or up to 1 year, whichever comes first | As determined by Article 18 of the LGPD and considering the retention period for providers provided for by the Brazilian Civil Rights Framework for the Internet (Law No. 12,965/2014). |
About international data transfers
Due to the investor of NEW MAX is located in France (Solina Group Holding), the international transfer of Personal Data may be necessary to achieve the objective of carrying out and developing the activities of NEW MAX, including for global operations (sharing data with Solina Group Holding for the purpose of coordinating global operations, managing human resources, managing NEW MAX's operations in Brazil, and offering products and services). Furthermore, it may occur to ensure the purposes listed in this Policy, as well as to ensure the availability of and access to information (to allow the adoption of security measures and protocols to ensure data backup and prevent loss or theft).
When necessary and as applicable, the international transfer of Personal Data will be carried out by NEW MAX with support from the mechanisms provided for in the LGPD and applicable standards, in particular: (i) transfer to countries or international organizations that provide a level of protection of Personal Data adequate to the LGPD and other applicable standards, as recognized by an adequacy decision issued by the ANPD; or (ii) through the adoption of standard contractual clauses, in accordance with applicable regulations; or (iii) compliance with legal or regulatory obligations; execution of a contract or preliminary procedures related to a contract; regular exercise of rights in proceedings. Without prejudice, NEW MAX may also adopt other international transfer mechanisms provided for in the LGPD and other applicable rules.
Personal Data may be transferred and processed in different countries, depending on the need—for example, in countries where servers, data providers, applications, and services are located. NEW MAX and other companies in the Solina Group Holding Conglomerate.
Some countries where we may share data due to the operations of NEW MAX are:
- Investor – Solina Group Holding with centralized repository in France. Also in Ireland and Northern Europe due to the Power BI tool.
- Third-party platforms used by NEW MAX with servers hosted abroad: United Kingdom; United States;
- Import operations for products to the following countries: China, Germany, United States, Peru, and Spain;
- Export operation of products to the following countries: United States, Egypt, Hungary, Canada, Uruguay, Malaysia, Argentina.
The international transfer of Personal Data will be carried out for the period necessary to fulfill the purposes set forth in this Policy and in any contracts and/or agreements entered into with partners, suppliers, service providers, and/or customers. This period may vary depending on the nature of the data transferred and the applicable legal requirements.
About Cookies
Cookies are small files that allow information related to your computer and you, the user, to be stored, specifically when you visit the NEW MAX website. NEW MAXwebsite. Cookies help us determine how often our web pages are visited and the number of users. They also help us configure advertising based on user preferences.
We may use the information to identify and track the preferences of Internet users when they violate any security rules or engage in any activity that is detrimental to the proper functioning of the website, such as attempts to hack the service.
Thus, the NEW MAX uses the cookies described below to provide a better browsing experience, analyze website traffic, and personalize content and ads.
- Necessary cookies: These are required to enable basic website features, such as providing secure login or adjusting your consent preferences. These cookies do not store any personally identifiable data.
- Functional cookies: help perform certain functions, such as sharing website content on social media platforms, collecting feedback, and other third-party features.
- Analytical cookies: These are used to understand how users interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.
- Performance cookies: are used to understand and analyze key website performance metrics, which helps to provide a better user experience for visitors.
- Advertising cookies: are used to provide users with personalized ads based on the pages you have previously visited and to analyze the effectiveness of advertising campaigns.
- Uncategorized cookies: these are cookies that are being analyzed and have not yet been classified into a category.
We use user consent for cookies collected on our website, which is recorded and documented by the CookieYes tool. CookieYestool, by recording the user's anonymous IP number, country, consent status, date, and time of consent. This data is stored on Amazon Web Services, also known as AWS, which is a cloud computing services platform offered by Amazon.
After one (1) year, the user's consent is automatically deleted by the registration tool and used only in aggregate and anonymous form as part of statistics for the NEW MAX.
You can change your cookie preferences at any time by clicking on the CookieYes in the lower left corner of the website. This will allow you to revisit the cookie consent banner and change your preferences or withdraw your consent immediately.
Please note that the use of cookies allows us to offer you a better experience on our website. If you block cookies on our website, we cannot guarantee that all features will function correctly, and you may not be able to access certain tabs. In addition, it is very likely that certain functions and pages will not work properly.
It is important to clarify that the NEW MAX is not responsible for the use of cookies by third parties. Please be aware that cookies placed by third parties may continue to monitor your online activities even after you have left our website, so we recommend that you clear your browsing history regularly.
In addition, different browsers provide different methods for blocking and deleting cookies used by websites. You can change your browser settings to block/delete cookies. Below are links to support documents on how to manage and delete cookies from major web browsers.
How do we protect your personal data?
The NEW MAX makes every effort to ensure the protection of your personal data.
We have rules of good practice and governance that seek to prevent any type of illegality when processing personal data, mitigating the possibilities of misuse, interference, loss, unauthorized access, modification, or even disclosure of this stored information.
Our measures include best practices in information security and the implementation of access controls to technology environments controlled by NEW MAX, as well as encryption, backup, pseudonymization, and anonymization of personal data whenever possible, and end-to-end encryption in communications via WhatsApp.
Access to your personal data is only permitted among our employees, suppliers, and partners on a need-to-know basis and is subject to strict contractual confidentiality obligations when processed by third parties.
Rights of the Data Subject
It is worth noting that you may contest the aforementioned processing at any time. To exercise your right, please contact our Data Protection Officer (DPO) by email at dpo@newmaxindustrial.com.br.
According to the legislation (Article 18, LGPD), below is a list of rights that data subjects may request:
I – Confirmation of the existence of treatment;
II – Access to data;
III – Correction of incomplete, inaccurate, or outdated data;
IV – Anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
V – Portability of data to another service or product provider, upon express request, in accordance with national authority regulations, observing commercial and industrial secrets;
VI – Deletion of personal data processed with the consent of the data subject, except in the cases provided for in the LGPD;
VII – Information on public and private entities with which the controller has shared data;
VIII – Information about the possibility of not providing consent and the consequences of refusal;
IX – Revocation of consent, under the terms of the LGPD; and
XX – Review of automated decisions.
If deletion/removal is requested, the NEW MAX may opt instead to anonymize personal data for the purposes of controlling and classifying demand.
We emphasize that we may retain certain data and/or continue to process it, even in the event of a request for deletion, opposition, blocking, or anonymization, in certain circumstances, such as to comply with legal, contractual, and regulatory obligations, to safeguard and exercise the rights of NEW MAX, users, and customers, to prevent illegal acts, and in judicial, administrative, and arbitration proceedings, including in other cases provided for by law.
Talk to our Data Protection Officer/DPO
If you have any questions about the processing of your personal data, please contact our Data Protection Officer (DPO):
Company: Vexia Administradora LTDA
Responsible: Álvaro Fernando Barros Villalobos
Address: Rua do Marceneiro, 179 – Jardim Werner Plaas, Americana – SP, CEP 13.478-722
Email: dpo@newmaxindustrial.com.br
Links to other websites
Our platforms may contain links to other applications, external websites, partners, and/or sponsors, which may have privacy policies that differ from ours and are therefore subject to their own data collection and use practices.
Therefore, we recommend that our users always read the specific privacy policy within the application or website of the partner or sponsor that collects their information.
Changes to the Privacy Policy
This Privacy Policy may be modified and updated at any time, whenever necessary. Any changes will be immediately communicated to you via on-screen notification (push), email, or other means that ensures full access to the new content.
Use of the website and platforms after a change in the Privacy Policy constitutes tacit acceptance of the new conditions.
Glossary and additional information
Personal data | According to the law, this refers to “information related to an identified or identifiable natural person.” Anything that can directly or indirectly identify a person, such as name, document numbers, photographs, biometric records, etc.; or, indirectly, data that can be cross-referenced or that can lead to information, such as a corporate email address or IP address. |
Anonymized data | This is data relating to the data subject without their direct identification, considering the technical means available at the time of processing. It is usually data used for research and public policy. |
Sensitive data | This refers to personal data about racial or ethnic origin, religious beliefs, political opinions, membership in a union or religious, philosophical, or political organization, data related to health or sex life, genetic or biometric data, when linked to a natural person. |
Personal Data Processing Manager | Person appointed by the controller to act as a communication channel between the controller, data subjects, and the National Data Protection Authority. |
Owner of personal data | The data subject covered by the law is always a natural person: "the natural person to whom the personal data being processed refers." |
Processing of personal data | Processing is the term used in the law that serves as an umbrella for a series of procedures involving data. Examples of processing actions: Collection / Production / Reception / Classification / Use / Access / Reproduction / Transmission / Distribution / Processing / Filing / Storage / Disposal / Evaluation / Control / Modification / Communication / Transfer / Dissemination / Extraction. |
For more information on the legislation:
http://www.planalto.gov.br/ccivil_03/_ato2015-2018/2018/lei/L13709.htm
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