Privacy & Data Governance
MANTRAC GROUP DATA PRIVACY STATEMENT (INCORPORATING DELTA GROUP) (EXCLUDING HR DATA)
LAST UPDATED: November 21, 2018
• What is the Purpose of this Document? • Data Protection Principals • The Kind of Information we hold • How is your Information collected? • How will we use Information about you? • How we use particularly sensitive Personal Information? • Data Sharing • Data Security • Data Retention • Rights of Access, Correction and Restriction • Right to withdraw consent • Contacting Us
1. WHAT IS THE PURPOSE OF THIS DOCUMENT? Mantrac Group Companies (UHL, subsidiaries and associated companies within Egypt under beneficial control) are committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR). It applies to all Customers, Prospective customers and suppliers. Mantrac Group Companies are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
2. DATA PROTECTION PRINCIPLES We will comply with data protection law. This says that the personal information we hold about you must be: 1. Used lawfully, fairly and in a transparent way. 2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes. 3. Relevant to the purposes we have told you about and limited only to those purposes. 4. Accurate and kept up to date. 5. Kept only as long as necessary for the purposes we have told you about. 6. Kept securely. 7. Not transferred to any third parties other than in accordance with applicable regulations. 8. Held in a manner which enables you to exercise certain rights (as outlined below) in connection with the information we hold relating to you.
3. THE KIND OF INFORMATION WE HOLD ABOUT YOU Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). Samples of data we may collect include, but are not limited to:
Customers: We may collect, store, and use the following categories of personal information about you: • Business Contact Information (e.g., company name, address, telephone number); • Individual Representative Contact Information: (e.g., name, address, telephone number, email address); • Billing Information (e.g., financial account data, invoices, receipts); • Client Relationship Management Information (e.g., information necessary to populate a customer’s profile or to facilitate marketing automation); • Repair Information (e.g., repair needs and status); • Warranty Information (e.g., purchase history, extended warranties); and • Customer Satisfaction Information.
Prospective Customers: We may collect, store, and use the following categories of personal information about you: • Business Contact Information (e.g., company name, address, telephone number); • Individual Representative Contact Information: (e.g., name, address, telephone number, email address); and • Client Relationship Management Information (e.g., information necessary to populate a customer’s profile or to facilitate marketing automation).;
Suppliers: •Residency Information (e.g., work permit status); •Financial Account Information; •Background Information (e.g. due diligence); •Professional Qualifications Information (e.g., work experience, education); and •Reference Information (e.g., letters of recommendation or reference, or reports provided by former employers or colleagues).
Additionally, in some cases, such as where you are the sole proprietor of a business, information about your company may be deemed personal information. This could include business information (e.g., office address), financial account information (e.g., bank account information, trade references, financial statements), assets (e.g., property ownership), credit rating, tax identification, and diversity classification.
There are “special categories” of more sensitive personal data which require a higher level of protection.
We may also collect, store and use the following “special categories” of more sensitive personal information: •Background Information (e.g., marital status, dependent information, ethnicity and/or nationality, credit and criminal background checks, and drug and alcohol testing); and •Biometric Information (e.g., thumbprints).
4. HOW IS YOUR PERSONAL INFORMATION COLLECTED? Mantrac Group collects personal information in a variety of contexts from different categories of persons.
Customers: (either directly or, in some cases, through third parties) can provide personal information through the business relationship involved in acquiring, marketing, or selling products or services. This includes, for example, submission of personal information as part of a proposal, a contract, receiving and employing services or products (including repair and warranty services), and potentially accessing systems or monitoring processes. Throughout the duration of a customer relationship, Iratrac reserves the right to request, as needed, other forms of personal information necessary to facilitate the purposes described below.
Prospective Customers: (either directly or, in some cases, through third parties) can provide personal information by contacting Mantrac Group directly in person or via electronic means (web sites etc). In addition, Mantrac Group may obtain such information from publicly available sources (the web, trade directories etc).
Suppliers: can provide personal information through the business relationship involved in acquiring, marketing, or selling Iratrac supplied products or services. This includes, for example, submission of personal information as part of a proposal, a contract, delivering services or products, and potentially accessing systems or monitoring processes. Throughout the duration of a supplier relationship, Caterpillar reserves the right to request, as needed, other forms of personal information necessary to facilitate the purposes described below.
Mantrac Group processes your personal information where it is permitted to do so under applicable data protection laws, including for the purposes of its legitimate interests, to comply with a legal obligation, or where you have consented for Iratrac to do so. In some cases, your consent to the collection of your personal information may be provided in a manner appropriate to the context, meaning it can be provided orally, in writing, electronically, or—when permitted by local laws—it may be implied where the purpose is apparent from the circumstances and you voluntarily provide your personal information. Where Iratrac must obtain explicit consent from you. Such consent is your choice and is entirely voluntary. In some circumstances, you may withdraw your consent to Iratrac’s collection and use of personal information subject to contractual and legal restrictions and reasonable notice.
5. HOW WE WILL USE INFORMATION ABOUT YOU
5.1 Situations in which we will use your personal information We need all the categories of information collected primarily to allow us to manage our relationship with you in order to operate our business and to enable us to comply with our legal and regulatory obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.
The reasons for which we, or a contracted third party, will process your personal information are listed in Table 1 below. Some of those purposes for processing will overlap and there may be several purposes which justify our use of your personal information.
Table 1. Categories, Purpose, and Legal Bases of Processing: Non-Human Resources Data
Data Subjects Categories of Personal Data
Purposes of Processing Legal Basis for Processing
Customers and Suppliers
Contact Information (e.g., name, address, telephone number, company name) Billing information (financial accounts data, invoices receipt, residence information) Client Relationship Management information Electronic identification information (e.g., email), system usage and preferences
Facilitate communications Evaluation and potentially entering into a business relationship or contract, including potentially preparing bids (responses to bids) and other requests that relate to the potential business To facilitate financial transactions and management; Audit Fulfilling our compliance obligations (e.g., anti-money laundering, screening against sanctions lists) Management of our IT systems and to provide services
Performance of a contract Comply with legal requirements Legitimate interest (to manage the relationship)
Customers Contact information (e.g., name, address, telephone number, company name) Billing information Credit worthiness Electronic identification information (e.g., email), system usage and preferences
Repair and Warranty Information Conducting credit reference checks and financial due diligence Performing customer satisfaction survey Perform data analysis to improve our service and your experience as a customer
Performance of a contract Legitimate interest (to receive feedback on customers experiences)
Prospective Customers and Subscribers to
Contact Information (e.g., name, address,
To inform you about our activities, sending you our newsletter, sending you our
Legitimate interest (communicating about related our newsletters or other marketing activities telephone number, company name) Electronic identification information (e.g., email) and preferences
reports, share exciting new information about our products
products or services) Consent
5.2 If you fail to provide personal information If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing you with a product), or we may be prevented from complying with our legal or regulatory obligations.
5.3 Change of purpose We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION ” Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances: 1. In limited circumstances, with your explicit written consent. 2. Where we need to carry out our legal obligations and in line with our Data Protection Policy. Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
6.1 Do we need your consent? We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights. In limited circumstances, we may approach you for your written or other explicit consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is your choice if you agree to any request for consent from us.
7. AUTOMATED DECISION-MAKING Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances: 1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights. 3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights. If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
8. DATA SHARING We may have to share your data with third parties, including manufacturers, suppliers, thirdparty service providers and between legal entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information in or outside of the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
8.1 Why might you share my personal information with third parties? We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
8.2 Which third-party service providers process my personal information? “Third parties” include third-party service providers (including contractors and designated agents). Selected activities are carried out by third-party service providers which include (but are not limited to), surveys and telesales.
8.3 How secure is my information with third-party service providers? All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions
8.5 What about third parties? We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
8.6 Transferring information outside the EU We may transfer the personal information we collect about you between Group Companies in the following countries outside the EU; Egypt, Kenya, Tanzania, Uganda, Ghana, Nigeria, Sierra Leone, Liberia, UAE and Iraq . This transfer is covered by an agreement between Unatrac Limited and Unatrac Holding Limited, its subsidiaries and companies in Egypt under beneficial control inclusive of model clauses. Transfer of data to other countries will also be covered by similar agreements.
9. DATA SECURITY We have put in place measures to protect the security of your information. Details of these measures may be obtained by emailing datagovernance@iratracgroup.com Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained by emailing datagovernance@iratracgroup.com We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
10. DATA RETENTION 10.1 How long will you use my information for? We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available on request by e mailing datagovernance@iratracgroup.com. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
11. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
11.1 Your duty to inform us of changes It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
11.2 Your rights in connection with personal information Under certain circumstances, by law you have the right to: • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. • Request the transfer of your personal information to another party.
11.3 No fee usually required You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded, excessive or unduly repetitive. Alternatively, we may refuse to comply with the request in such circumstances.
11.4 What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
12. RIGHT TO WITHDRAW CONSENT In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact datagovernance@iratracgroup.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
13. CHANGES TO THIS PRIVACY NOTICE We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
MANTRAC GROUP DATA GOVERNANCE STATEMENT (INCORPORATING DELTA GROUP)
LAST UPDATED: November 21, 2018
• What Information We Collect • How We Collect Information • How We Use Information • How We Disclose Information • Security • Personal Information Choices and Access • Other Important Information • Updates to this Data Governance Statement • Contacting Us
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.
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 Iratrac 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 Iratrac 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
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 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 Iratrac 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 Iratrac Data Privacy Policy.
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.
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.
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.
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.
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 datagovernance@iratracgroup.com