Data Governance Statement

Last updated: November 21, 2018

This Data Governance Statement describes the practices of Mantrac Group Companies (UHL, subsidiaries and associated companies within Egypt under beneficial control) for collecting information from customers and suppliers relating to machines, products or other assets and their associated worksites (collectively “Assets”), and customers or potential customers either directly or via suppliers. We collect this information through online and offline means including: (1) applications and platforms for use on or through computers, APIs, and mobile devices ("Applications"); (2) telematics or other devices on Assets (“Devices” and, together with the Applications, “Digital Offerings”); and (3) suppliers, service providers, and customers.

You should regularly review this Statement carefully to understand what information our digital offerings receive, generate and transmit—and what we do with that information. By providing System Data, Operations Data, or Personal Information (each as defined below) to us, you agree to the terms and conditions of this Data Governance Statement, including our collection, use and sharing of that information.

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WHAT INFORMATION WE MAY COLLECT

“Personal Information” is any information about a specific individual or that identifies or may identify a specific individual, as further described in the Mantrac Group Data Privacy Statement. While this Data Governance Statement includes references to Personal Information for purposes of clarity and transparency, the Mantrac Data Privacy Statement and the privacy notice applicable to your Digital Offerings, will govern our conduct in respect of the matters described in those documents, including the collection, use, transfer, disclosure and management of Personal Information. Nothing in this Data Governance Statement is intended to modify the Mantrac Data Privacy Statement or any applicable privacy notices.

"System Data" is information that is ingested or used by or generated through Digital Offerings, which may include:

Device, Asset and Component Information, including model number, serial number, order number, software and hardware version numbers, performance, and configuration, including work tools or other peripheral devices attached to Assets.
Electronic Data, including sensor logs, trends, histograms, event data, other alerts, digital state data, fault codes, idle time, daily and cumulative fuel consumption, emissions data, service meter hours, electronic data files downloaded manually or automatically from an Asset, troubleshooting data, and other data, depending on the customer and Asset and communication channel used by a Device.
Inspection Data, including results of inspections using a Caterpillar or third-party inspection system.
Device Location Information, including the physical location of an Asset (e.g., determined using satellite, GPS, cell phone tower, Bluetooth or WiFi signals).
Fluid Data, including analysis results of fluid samples (such as oil, hydraulic and coolant fluids) obtained using Caterpillar or third-party tools.
Event Recorder Data, including location, speed, direction and associated video recordings, use of controls and positive train control information.
Service and Maintenance History, including work orders (records of all maintenance, repair, parts purchases, replacement and modification to an Asset), component life (history of usage and wear life of a component), maintenance schedule, planned maintenance, warranty coverage data, maintenance and repair contracts, service intervals (scheduled interval for planned maintenance of component replacement activities for an Asset), component lists (lists of parts that make up an Asset) and service letters (describing special service actions recommended by Caterpillar to correct a known problem with an Asset).
Site and Environmental Conditions, including the type of work being done, condition of roads or tracks, altitude, climate and material tracking.
Patterns of Use, including any user-defined information relating to a product you provide to us through a Digital Offering.

"Operations Data" is additional information we may collect from or that is otherwise provided by Distribution Networks, which may include:

Information contained in invoices and service contracts.
Information about customers of Distribution Networks, including certain Personal Information relating to such customers or their dealer sales representatives.
Work order data, including information about the customer, Asset involved, problem identified, and repairs performed.
Information collected may simultaneously constitute System Data, Personal Information, and Operations Data, or any combination thereof. Data sourced from customers and suppliers relating to Assets, and customers either directly or via suppliers will be stored to help serve their business needs. All data will be collected subject to the rights covered in the section of this document under Personal Information Choices and Access.

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HOW WE MAY COLLECT INFORMATION

We and our service providers may collect information in a variety of ways, including:

Through Devices: We may receive information via cellular or satellite link, or radio or Ethernet connection from Assets equipped with a Device, which may include System Data, (such as information relating to the Device or Asset), or Personal Information, (such as from information generated by fatigue monitoring devices, on-board camera and proximity detection systems, and in-cab monitoring technology). Some information may be collected automatically, such as fault codes, hours of operation and fuel levels.
Through Applications and Online: We may collect information through Applications (e.g., when you enter maintenance information) or when you use our websites, online services or platforms. We may also receive information through other online means, such as when you initiate a data transmission through on-site servers or email inspection information to us. We may also collect information typically collected through websites and mobile applications, such as browser and device information, application usage data, information collected through cookies, pixel tags and other technologies, IP addresses and location information.
Offline: We may collect information when you interact with us or our Distribution Networks, attend one of our trade shows, place an order or contact customer service.
From Component Manufacturers and OEMs: We may obtain System Data from manufacturers of the components in your Assets or of Assets manufactured by others you use. This information may be provided to us automatically.
Through Wearable Technology: We may collect information through wearable technology, such as fatigue monitoring devices or RFID tags embedded in hardhats or safety vests.
From Asset Owners, Distribution Networks and Others: We may receive additional information from Asset owners, Distribution Networks, operators and other persons who have management responsibility for an Asset.
From Other Sources: We may receive your information from other sources, such as public databases, joint marketing partners, social media platforms, (including from people with whom you are friends or are otherwise connected), and from other third parties. We may collect or generate information from troubleshooting data, from your service providers, (such as fluid analysts and site inspectors), or from maintenance, inspection or warranty records.

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HOW WE MAY USE INFORMATION

We may, and may permit our Distribution Networks to, use collected information for the following purposes:

To Provide Services to You and Others:

To allow you or us to monitor the status of Assets, to provide you use of Applications, to complete and fulfill purchases, and to communicate with you regarding your purchase or rental and provide you with related customer service.
To fulfill customer support agreements, perform maintenance and repairs and deliver rental Assets or parts.
To make recommendations regarding safety, Asset health, maintenance, worksite efficiency and productivity training for operators.
To enhance the safety of machine operations, including by tracking proximity to Assets, other objects or humans.
To enable remote technician services, such as remote troubleshooting, and remote tuning.
To provide you with location-based services and content.

To Enable Communications:

To manage the connection to the Asset or Device. To allow you and other users of Applications to communicate with each other through Applications.
To send administrative or contractual information, for example, information regarding the terms and conditions of using Digital Offerings, warranty policies or service contracts.
To provide you with information about new products and services and to send you marketing communications that we believe may be of interest to you.

For General Business Purposes:

To conduct market research.
To perform data analytics, audits, improving products, developing new products, enhancing, improving or modifying our Digital Offerings, identifying usage trends and operating and expanding our business activities and for statistical analysis based on aggregated and de-identified data, such as benchmarking reports.
To provide services to customers, manage work flow, monitor repairs, project future maintenance and service, and troubleshoot issues.
To validate effectiveness of recommendations, resolve complaints, and fulfill orders.
To manage inventory so we can provide you parts and services.
To manage a fleet of owned or rented Assets.
To maximize the efficiency of operations and increase sales.
To develop digital applications.

Other Uses:

To allow you to participate in sweepstakes, contests or similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information. We suggest that you read any such rules carefully, including the Mantrac Data Privacy Policy and any applicable privacy notices.

For additional uses as agreed by you and us.

With respect to audiovisual data that identifies an individual or physiological data for an identifiable individual, we will use that data only to provide products and services to our customers, including to make recommendations regarding safety, Asset health, maintenance, worksite efficiency and productivity training for operators, and to improve our products and services. Personal Information use in this regard will be governed by the Mantrac Data Privacy Policy.

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HOW WE MAY DISCLOSE INFORMATION

We may disclose information:

To Suppliers to permit them to use System Data and Personal Information for product development purposes.
To Asset owners, to permit them to manage their use of their Asset.
To our service providers who provide services such as data analytics, information technology and related infrastructure provision, application development, platform hosting, customer service, product development, auditing, advisory and other services.
To component manufacturers, to permit them to study the use of their products, to improve their products and to develop new products.
To agents, service providers or other third parties contracted by or engaged in business with Asset owners, who have management responsibility for the Asset.
To a third party in the event of reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our or any of our Affiliate’s business, Assets or stock (including in connection with any bankruptcy or similar proceedings).
To make data available consistent with this Data Governance Statement through the developer portals operated by the manufacturers of the products which we supply to you or other similar APIs.
In order to comply with any legal or regulatory obligations to which we are subject, including by disclosing information to any court, tribunal or other regulatory or governmental authority.
To additional recipients as agreed by you and us.

De-identified or Aggregated Information: We may use and disclose de-identified or aggregated information (i.e., information that does not identify you or any other user of the Digital Offerings) for any purpose, except where we are required to do otherwise under applicable law.

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SECURITY

We use reasonable organizational, technical and administrative measures designed to protect information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below. Our Data Security Policy can provide further information in this regard.

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PERSONAL INFORMATION CHOICES AND ACCESS

Please refer to the Mantrac Group Data Privacy Statement and any applicable privacy notices to understand your rights and choices regarding our use and disclosure of your Personal Information.

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OTHER IMPORTANT INFORMATION

Third Party Content: This Data Governance Statement does not address, and we are not responsible for (i) the privacy, information or other practices of any third party operating any website or online service to which a Digital Offerings links (e.g., our Applications may include, for your convenience, a hyperlink to local weather information provided by a third party with whom we have no business relationship) and (ii) Personal Information controlled by a third party, such as a supplier, service provider, or customer, even if such Personal Information is collected or otherwise processed by us or such third party. Further, the inclusion of a link in a Digital Offering does not imply endorsement of the linked site or service by us or by our affiliates.

Cross Border Transfers: Your information may be stored and processed in any country where we operate or where our service providers operate, and by using a Digital Offering or otherwise providing data to us consistent with this Data Governance Statement you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. Cross Border Transfers will be covered by relevant non-disclosure agreements between us and the recipient or under Model Clauses in compliance with relevant laws.

Sensitive Information: Our Digital Offerings are not designed for you to send us sensitive Personal Information such as social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, or genetic characteristics, criminal background or trade union membership. We request that you refrain from sending such information on or through Digital Offerings or otherwise to us.

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UPDATES TO THIS DATA GOVERNANCE STATEMENT

We may change this Data Governance Statement. The “LAST UPDATED” legend at the top of this page indicates when this Data Governance Statement was last revised. Any changes will become effective when we post the revised Data Governance Statement. Your use of Digital Offerings following these changes means that you accept the revised Data Governance Statement.

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CONTACTING US

If you have any questions about this Data Governance Statement, please contact us at [email protected]