Privacy Notice

Last updated: November 01, 2022

Maxion Wheels respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.

We recommend that you read this Privacy Notice in full to ensure you are fully informed.

If you are residing or located in EEA (European Economic Area) or Brazil, you may have specific rights regarding the processing of your personal information, please, consult our EEA Addendum or our Brazil Addendum.

The personal information that we may collect about you are those that are compatible and necessary to enable your relationship with us (e.g., whether you are an investor, service provider, customer contributor, business partner, visitor to our website, among others). They broadly fall into the following categories:

• Identification information
  We may need some information like your name, ID, gender, birth date, marital status, nationality, among others.
   
• Information that will help us to contact you
  These information like your address, zip code, phone number or cellphone number and e-mail, will help us reach you when needed.
   
• Information that we collect automatically
  When you visit our Website, we may collect certain information automatically from your device.
  
  Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g., country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.
  
  Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.

In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

We may disclose your personal information to the following categories of recipients:

• to our GROUP COMPANIES, THIRD PARTY SERVICES PROVIDERS AND PARTNERS who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
• to any COMPETENT LAW ENFORCEMENT BODY, REGULATORY, GOVERNMENT AGENCY, COURT OR OTHER THIRD PARTY where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to an actual or POTENTIAL BUYER (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
• to any OTHER PERSON WITH YOUR CONSENT to the disclosure.

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our website and communicating with you as necessary to provide information to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our website, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at dataprivacy@iochpe.com.br.

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.

We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include encrypting your personal information in transit.

Beside those measures, we also use substantial technical measures that guarantee a higher level of security of your personal information. Such as:

• Strict control of the Personal Data Processing, including access limitation, and password-protected access;
• Access authentication mechanisms, which ensure the individualization of records;
• Detailed inventory of connection records, including timing, duration, and identity of the person responsible;
• Some applications offer solutions for managing records by storing access logs, without prejudice to use of other technical standards later stipulated by the competent authorities.

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our Website servers are located in United States and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information, we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

As an international company, Maxion Wheels operates in countries that may have laws regarding data protection, in these cases, we make sure that your rights as a data subject are respected.

When we receive a request, we may ask for additional data from you to confirm your identity. In some situations, we may deny to act or we may impose limitations on your rights as permitted by the applicable law, explaining to you the reasons that excused the non-compliance of your request, such as requests involving Personal Data and/or documents from other Subjects, or when we act as Processors.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

If you are residing or located in EEA (European Economic Area) or Brazil, please, consult our EEA Addendum or our Brazil Addendum.

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

If you have any questions or concerns about our use of your personal information, please contact us using the following details: dataprivacy@iochpe.com.br.

The data controller of your personal information is Iochpe-Maxion S/A.

If you are a resident of the European Economic Area, you have the following data protection rights:

• If you wish to ACCESS, CORRECT, UPDATE OR REQUEST DELETION of your personal information, you can do so at any time by contacting us at dataprivacy@iochpe.com.br.
• In addition, you can OBJECT TO PROCESSING of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us at dataprivacy@iochpe.com.br.
• You have the right to OPT-OUT OF MARKETING COMMUNICATIONS we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us at dataprivacy@iochpe.com.br.
• Similarly, if we have collected and process your personal information with your consent, then you can WITHDRAW YOUR CONSENT at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the RIGHT TO COMPLAIN TO A DATA PROTECTION AUTHORITY about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area are available here.)

If you are residing in Brazil, or located in Brazil at the time of collection of your personal information, you have the following data protection rights:

• If you wish to CONFIRM the existence of processing of your personal information, you can do so at any time by contacting us at dataprivacy@iochpe.com.br.
• If you want to KNOW WITH WHOM we share your personal information contact us at dataprivacy@iochpe.com.br.
• If you want to ACCESS, CORRECT, UPDATE OR COMPLETE your personal information, feel free to do so at any time by contacting us at dataprivacy@iochpe.com.br.
• Also, you can request the anonymization, blocking or delete of unnecessary, excessive, or illegally processed personal information, contacting us at dataprivacy@iochpe.com.br.
• In addition, you can request the portability of your personal information to another service or product supplier, upon your express request. Again, you can exercise these rights by contacting us at dataprivacy@iochpe.com.br.
• You have the right to request the review of automated decisions, please contact us at dataprivacy@iochpe.com.br.
• Similarly, if we have collected and process your personal information with your consent, then you can WITHDRAW YOUR CONSENT at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the RIGHT TO COMPLAIN TO A DATA PROTECTION AUTHORITY about our collection and use of your personal information. For more information, please contact the Brazilian National Data Protection Authority (“Autoridade Nacional de Proteção de Dados” – “ANPD”).

Terms & Conditions

Our policies and practices are intended to avoid misunderstandings and to provide reasonable protection for us. We urge you to carefully consider the following terms and conditions before submitting your idea to us because you must agree with these terms and conditions to submit your idea.

No Confidential Relationship

Iochpe-Maxion S.A. (and its affiliates, hereinafter “the Company”) does not wish to receive or maintain any information "in confidence." Therefore, by submitting your information, you acknowledge and agree that your submission to the Company does not create a confidential, fiduciary, or other special relationship between you and the Company. The Company has the right, but not the obligation, to use your name, likeness, or any other information about you, in connection with the use of the submitted information and material.

Ownership and Usage rights of submitted content

Your submission and its contents  automatically become the property of the Company, without any compensation of any kind owed to you;

The Company may use or redistribute your submission and its contents for any purpose and in any way, including but not limited to using it in new products or services of the Company, or to improve existing products or services of the Company.

Acknowledgements by Submitter

You acknowledge that the Company may already be aware of the idea that you are submitting.
You agree that the Company reserves the right to contest the validity, infringement, or enforceability of any patent, including your own.
You agree that with the exception of a claim for patent infringement, the Company shall have the unrestricted right to use and disclose, at no cost, any submitted materials and information.
By making a submission, you acknowledge and agree that the Company and its designees may create on their own or obtain many submissions that may be similar or identical to the materials you submit. You hereby waive any and all claims you may have had, may have, and/or may have in the future, that the materials accepted, reviewed and/or used by the Company and its designees may be similar to your Materials.

Merger of Any Previous Negotiations or Agreements

Any prior negotiations or agreements are merged into and superseded by these terms, which may not be modified or waived except in writing signed by a company officer or the Company's General Counsel.