Privacy and Cookie Policy

1. Data controller

Max Del Indústria Metalúrgica Ltda., a 100% Brazilian company operating in the fastener market for over 40 years, is the controller of the personal data processed through this website.

• Legal name: Max Del Indústria Metalúrgica Ltda.
• Address: Rua Lúcia Mormito Biason, 204 – Bairro Sertãozinho – Mauá/SP – Brazil
• Phone: +55 11 4544-1600
• E-mail: contato@maxdel.ind.br

2. Data Protection Officer

To exercise your rights, clarify doubts about this Policy or file a complaint regarding the processing of personal data, please contact our Data Protection Officer:

• Data subject channel: contato@maxdel.ind.br
• Phone: +55 11 4544-1600
• Mail: Rua Lúcia Mormito Biason, 204 – Bairro Sertãozinho – Mauá/SP – Brazil (Attn.: Data Protection Officer – LGPD)

3. Personal data we collect

We only collect the data required for the purposes described in this Policy:

Source	Data processed	How it is collected
Website browsing	IP address, date and time of access, pages visited, browser and device type, operating system, traffic source and cookie identifiers.	Automatically, through cookies and server logs.
“Contact us” form	Name, e-mail, phone number and the content of your message.	Voluntarily provided by you.
“Work with us” form	Name, e-mail, phone number, résumé and any other professional information you choose to attach.	Voluntarily provided by you.
Direct business contact	Name, job title, company, corporate e-mail and phone number.	Provided by you when contacting us by e-mail or phone.

We do not intentionally collect sensitive personal data (article 5, II, of the LGPD) through this website. Please do not include such information in the free-text fields of our forms.

4. Purposes and legal bases

Purpose	Legal basis (article 7 of the LGPD)
Responding to requests, quotations and questions received through our contact channels.	Preliminary procedures related to a contract (item V) and legitimate interest (item IX).
Managing recruitment processes and assessing applications.	Preliminary procedures related to a contract (item V) and consent (item I) for keeping résumés in our talent pool.
Keeping the website operational, secure and available.	Legitimate interest (item IX) and compliance with legal obligation (item II).
Measuring page audience and performance (browsing statistics).	Consent (item I), given through the cookie banner.
Displaying embedded third-party content, such as the location map.	Consent (item I), given through the cookie banner.
Complying with legal, regulatory and audit obligations, including management certification requirements.	Compliance with legal or regulatory obligation (item II).
Exercising rights in judicial, administrative or arbitration proceedings.	Regular exercise of rights (item VI).

5. Data sharing

Max Del does not sell or trade personal data. Sharing only occurs when necessary and is limited to the strict minimum, with:

• Technology suppliers: website hosting providers, e-mail services and the agency responsible for website maintenance, acting as processors under our instructions.
• Google LLC: through Google Analytics (browsing statistics) and Google Maps (location map), when you authorise the corresponding cookies.
• Public authorities: where required by law, court order or request from a competent authority.
• Group companies, customers and partners: only where strictly necessary to handle your request.

6. International data transfers

Some of the services we use, such as Google Analytics and Google Maps, may process data on servers located outside Brazil. In such cases, the transfer is based on the grounds set out in article 33 of the LGPD and relies on the contractual safeguards offered by the respective suppliers.

7. Retention periods

• Contact messages: for as long as needed to handle your request and, afterwards, for up to 5 years for evidence and defence of rights.
• Résumés: for up to 2 years from submission, where consent has been given for inclusion in our talent pool.
• Website access logs: for 6 months, under article 15 of the Brazilian Internet Act (Law No. 12,965/2014).
• Cookie consent record: for 180 days, after which you are asked again.

Once the periods and purposes have been fulfilled, data is deleted or anonymised, unless the law allows its retention.

8. Information security

Protecting the data and information of customers, suppliers, employees and other interested parties is a formal commitment of Max Del's Integrated Management Policy. We adopt technical and administrative security measures proportionate to the risk, including access control, internal policies, employee training and incident monitoring. Should a security incident involving relevant risk to data subjects occur, we will notify the Brazilian Data Protection Authority (ANPD) and the affected data subjects, pursuant to article 48 of the LGPD.

9. Your rights as a data subject

Under article 18 of the LGPD, you may request at any time:

• Confirmation that processing exists and access to your data;
• Correction of incomplete, inaccurate or outdated data;
• Anonymisation, blocking or deletion of unnecessary or excessive data, or data processed in breach of the law;
• Data portability to another provider, upon express request;
• Deletion of data processed on the basis of consent;
• Information about the public and private entities with which we share data;
• Information about the possibility of refusing consent and the consequences of such refusal;
• Withdrawal of consent at any time, free of charge and through a simplified procedure.

To exercise any of these rights, write to contato@maxdel.ind.br. We will reply as soon as possible, within the statutory deadlines. We may request additional information to confirm your identity and prevent improper disclosure of data to third parties.

10. Cookie Policy

Cookies are small files stored in your browser when you visit a website. They allow the site to work properly, remember your choices and produce usage statistics.

On your first visit, a notice is displayed where you may accept all cookies, reject non-essential cookies or manage your preferences by category. Non-essential cookies remain blocked until you give your consent.

Category	Purpose	Examples and lifetime
Strictly necessary (always active)	Ensure website browsing and security and record your cookie choice.	maxdel_consentimento – 180 days.
Performance and statistics (optional)	Measure visits, most viewed pages and traffic sources on an aggregated basis.	Google Analytics: _ga, _gid, _gat, __utma, __utmb, __utmc, __utmz – from a few minutes to 2 years.
Third-party content (optional)	Load embedded resources from other companies, such as the plant map on the contact page.	Google Maps – lifetimes defined by Google LLC.

You may change or withdraw your choice at any time by clicking Cookie preferences, available in the footer of every page. You may also block or delete cookies directly in your browser settings — in that case, some website features may stop working properly.

11. Children's data

This website is intended for a business audience and is not directed at children or teenagers. We do not knowingly collect data from individuals under 18. Should we identify such collection, the data will be deleted.

12. Changes to this Policy

This Policy may be updated to reflect changes in our activities or in applicable legislation. The date of the last update is shown at the beginning of this document. Material changes to purposes or cookie categories will be communicated through a new consent notice on the website.

13. Contact us

Questions, requests or complaints about privacy and data protection may be sent to contato@maxdel.ind.br or by phone at +55 11 4544-1600. You may also file a complaint directly with the Brazilian Data Protection Authority (ANPD) at www.gov.br/anpd.