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 * Caterpillar Inc
 * Legal Notices
 * Data Governance Statement




DATA GOVERNANCE STATEMENT

Last Updated: August 15, 2018


DATA GOVERNANCE STATEMENT

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This Data Governance Statement describes the practices of Caterpillar Inc.
(together with our Affiliates, “Caterpillar,” “we,” “us” or “our”) for
collecting information from distribution networks (including dealers and their
related entities, “Distribution Networks”), Affiliates (as defined below) and
each of our and their customers relating to machines, products or other assets
and their associated worksites (collectively “Assets”).  We collect this
information through online and offline means including: (1) applications and
platforms for use on or through computers, APIs, and mobile
devices; (2) telematics or other devices on Assets, whether manufactured by
Caterpillar or by other companies (“Devices” and, together with the
Applications, “Digital Offerings”); and (3) our Distribution Networks, component
manufacturers, service providers, and customers.  As used in this Data
Governance Statement, “you” means you individually and, as applicable, the
company or entity you represent and each of its employees, agents and
representatives. 

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.

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 Caterpillar Global Data Privacy Statement.  While this Data Governance
Statement includes references to Personal Information for purposes of clarity
and transparency, the Caterpillar Global Data Privacy Statement and
the privacy notice applicable to your Digital Offerings, are controlling with
respect to 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 Caterpillar Global 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 Wi-Fi 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 

 * Store hierarchy data, including information about dealer inventory reporting
   and replenishment processes.

 * Information used by Distribution Networks to manage a fleet of Assets (either
   owned or rental) including customers of Distribution Networks and worksites.

 * Dealer component data, including information relating to management and
   replenishment of parts inventory, and customer purchases, returns and
   replacements.

Information collected by Caterpillar may simultaneously constitute System Data,
Personal Information, and Operations Data, or any combination thereof. If you
submit any System Data, Operations Data, or Personal Information,
including System Data that may relate to Devices on Assets 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:

 * 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.

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 the dealer 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 or to evaluate Caterpillar or Distribution
   Networks.

 * 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 Caterpillar Global Data Privacy Statement 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.  

HOW WE MAY DISCLOSE INFORMATION

We may disclose information:

 * To the entities directly or indirectly controlling, controlled by or under
   common control with Caterpillar Inc. (“Affiliates”) for the purposes
   described in this Data Governance Statement.  Caterpillar Inc. is the entity
   responsible for information jointly used with its Affiliates. 

 * 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 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 Cat Developer Portal or other similar APIs.

 * To additional recipients as agreed by you and us.

Location Data: We may share location information with our Affiliates
and Distribution Networks to enable them to provide you with localized content
and services.  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.  

We may use or disclose information, 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 lawful 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 and
Distribution Networks; (f) to protect our rights, privacy, safety or property,
and/or that of our Affiliates, Distribution Network, 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.

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.

REMOTE SERVICES AND UPDATES

As further described in the Cat® Remote Services – Software Update Process for
select Product Link™ Telematics and Cat Equipment Control Module
Software, depending on your Device and Asset configuration, we may use System
Data to remotely:

 * Examine and update Devices that we manufacture or otherwise provide (e.g., to
   update system settings or to manage the communications carriers used to
   connect to Caterpillar or our Affiliates).

 * Update software that controls machine operations for your Cat Asset, and we
   may push the software update files to the Asset in preparation for an update.

Please refer to the Cat® Remote Services – Software Update Process for select
Product Link™ Telematics and Cat Equipment Control Module Software for
additional information on how we manage remote software updates and your choices
relating to remote software updates.

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.

PERSONAL INFORMATION CHOICES AND ACCESS

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

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 Caterpillar. 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.

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. 

Distribution Networks: Distribution Networks may have their own privacy
statements and data governance policies.  We encourage you to regularly review
such statements.  Such statements and policies are specific to the applicable
dealer and do not apply to our collection, use, disclosure or management
of information as described in this Data Governance Statement, the Caterpillar
Global Data Privacy Statement and any applicable privacy notices. 

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.

CONTACTING US

If you have any questions about this Data Governance Statement, please contact
us at CatDigitalSupport@Cat.com.

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