Data Privacy Governance Statement

 

DATA GOVERNANCE STATEMENT

This Data Governance Statement describes the practices of Caterpillar Inc. (“Caterpillar,” “we,” “us” or “our”) in connection with information that we collect through telematics or other devices on equipment, whether manufactured by Caterpillar or by other companies (“Devices”), through software applications to manage connected products made available by us for use on or through computers and mobile devices, such as Cat® Safety Services Fatigue Monitoring (the “Applications”) (collectively, with the Devices, the “Services”), as well as information relating to assets and their associated worksites provided to us by customers, distribution networks (including dealers) (“Distribution Networks”), component manufacturers and service providers.  By providing System Data or Personal Information to us, you agree to the terms and conditions of this Data Governance Statement, including our collection and use of such information, our sharing of information with Distribution Networks and other third parties, and our other practices described herein.

What System Data and Personal Information we may collect

System Data” is data that is ingested or used by or generated through our Services, which may include:

  • Device, Equipment 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 the equipment.
  • 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 the Device.
  • Inspection Data, including results of inspections using a Caterpillar or third-party inspection system.
  • Device Location Information, including the physical location of your connected product (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) provided to us 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, part, 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 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 data that do not relate to any particular individual, as well as any user-defined information relating to the connected product you provide to us through the Services. 

 

Personal Information” is information that relates to an identified or identifiable individual, which may include:

  • Name
  • Postal address (including billing and shipping addresses)
  • Telephone number
  • Email address
  • Username for Applications
  • Company, role and title
  • Services performed
  • User Profile information
  • User ID for engineers, operators of equipment or users of online Applications
  • Location information relating to a person
  • Information about any computer or mobile device with which you access Applications
  • Information about your use of the Applications
  • Audiovisual data that identifies an individual 
  • Physiological data such eye movement, facial expressions, heart rate 

 

If you submit any System Data or Personal Information in connection with the Services, including System Data that may relate to Devices or connected products that are not manufactured by Caterpillar, you represent that you have the authority to do so and to permit us to use the information in accordance with this Data Governance Statement.

How we may collect Information

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

  • From 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 Information such as Device, Equipment and Component Information or Personal Information from fatigue monitoring devices, on-board camera and proximity detection systems, and in-cab monitoring technology, such as the Driver Safety System.  Some information may be collected automatically, such as fault codes, hours of operation and fuel levels.
  • Through the Applications and Online: We may collect information through the Applications (e.g., when you enter maintenance information) or when you sign up for Cat® Safety Services Fatigue Monitoring or use our websites or other online services.  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 apps, 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 visit 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 equipment or of non-Caterpillar equipment 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 Equipment Owners, Distribution Networks and Others: We may receive additional information from asset owners, Distribution Networks, operators and other persons who have management responsibility for a connected product.
  • 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.

 

How We May Use Information

We may use information:

  • To Provide Services to You and Others:
    • To provide the Services (e.g., to allow you to monitor the status of assets, to manage inventory in order to provide you with parts and services, to provide you use of the Applications, to complete and fulfill purchases, and to communicate with you regarding your purchase and provide you with related customer service). 
    • To fulfill customer support agreements, perform maintenance and repairs and deliver rental equipment 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 equipment, other objects or humans.
    • To enable remote technician services, such as remote troubleshooting, and remote tuning by Cat Performance Experts.
  • To Enable Communications:
    • To manage the connection to the Device or connected product.
    • To allow you and other users of Applications to communicate with each other through the Applications. 
    • To send administrative or contractual information, for example, information regarding the terms and conditions of using the Services, 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 Our Business Purposes:
    • To conduct market research or to evaluate Caterpillar or our Distribution Networks.
    • For our other business purposes, such as data analysis, audits, improving products, developing new products, enhancing, improving or modifying our Services, 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.
  • Other Uses:
    • To provide you with location-based services and content.
    • 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.
    • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others, including for purposes of information security; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
    • For additional uses as agreed by you and us in any applicable agreement.

 

With respect to audiovisual data that identifies an individual or physiological data, 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.

 

How We May Disclose Information

We may disclose System Data and Personal Information:

  • To our affiliates, as detailed in our securities filings located at http://www.caterpillar.com/en/investors/sec-filings.html,  for the purposes described in this Data Governance Statement.  Caterpillar Inc. is the entity responsible for jointly used information.
  • To Distribution Networks to permit them to use System Data and Personal Information to maintain relationships with you, provide services to you and send marketing communications to you.
  • To equipment owners, to permit them to manage their use of their equipment.
  • To our service providers who provide services such as data analysis, information technology and related infrastructure provision, 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 of Caterpillar or other third parties contracted by or engaged in business with equipment owners, who have management responsibility for the connected product.
  • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
  • To additional recipients as agreed by you and us in any applicable agreement.

 

Location Data: We may share your physical location with our affiliates and Distribution Networks to enable them to provide you with localized information.  In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our affiliates and Distribution Networks may not be able to provide you with the applicable services and content. 

 

Remote Services and Updates

Device Software Maintenance: From time to time, we use System Data to remotely examine and update Devices that we manufacture (e.g., to update system settings or to manage the communications carriers used to connect to Caterpillar).  In doing so, we may change the volume or granularity of System Data that we collect in order to improve the utility of the Services to you, as well as to improve our products and services, among other purposes.  If the change in data we collect materially changes the scope of System Data, we will update this Data Governance Statement as described in “Updates to This Data Governance Statement” below.

 

Equipment Software Maintenance: In addition, we offer equipment owners the option to participate in our automatic update service for asset software. If you participate in this service, we will use System Data to remotely update software that controls machine operations for your Caterpillar asset, and we may push the software update files to the equipment in preparation for an update.

 

AGGREGATED Information

Aggregated Personal Information or System Data does not personally identify you or any other user of the Services (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code, or we may aggregate System Data to calculate component wear rates).  We may use and disclose aggregated information for any purpose, except where we are required to do otherwise under applicable law.

 

LINKS to THIRD‑PARTY Websites

This Data Governance Statement does not address, and we are not responsible for, the privacy, information or other practices of any third party operating any website or online service to which the Services link (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).  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. 

security

We use reasonable organizational, technical and administrative measures designed to protect System Data and Personal 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.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information.  You may opt-out from:

  • Receiving electronic marketing communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by emailing us at safetyservices@cat.com.  We will process your request(s) as soon as reasonably practicable.  Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
  • Our sharing of your Personal Information with our Distribution Networks for their direct marketing purposes: If you would prefer that we not share your Personal Information on a going-forward basis with our Distribution Networks for their direct marketing purposes, you may opt-out of this sharing by emailing us at safetyservices@cat.com.

How you can access, change or suppress your Personal Information 

If you would like to review, correct, update, suppress or delete Personal Information that you have previously provided to us, you may contact us by emailing us at safetyservices@cat.com

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed in our database.  For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will process your request as soon as reasonably practicable. 

Please note that we may need to retain certain information for recordkeeping purposes or in accordance with agreements we may have with a third party (e.g., an equipment owner or Distribution Network that employs you).  There may also be residual information that will remain within our databases and other records, which will not be removed.

RETENTION PERIOD

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Data Governance Statement unless a longer retention period is required or permitted by law. 

CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you expressly 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.

SENSITIVE INFORMATION

The Services 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 the Services or otherwise to us. 

UPDATES TO THIS DATA GOVERNANCE STATEMENT

We may change this Data Governance Statement.  The “Last Updated” legend at the bottom 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 on the Services.  Your use of the Services following these changes means that you accept the revised Data Governance Statement.

CONTACTING US

If you have any questions about this Data Governance Statement, please contact us at emailing us at safetyservices@cat.com.