Privacy Notice

Effective Date: 28/06/2019

This privacy notice describes how Caterpillar (Shanghai) Trading Co., Ltd. (“Caterpillar”, “We”, “we” or “us”) collects, processes and shares personal information through thecatpeijian.cn (“Site” or “this Site”). For purpose of this notice, Caterpillar also includes Caterpillar Inc. and its subsidiaries. This privacy notice is consistent with Caterpillar’s Global Data Privacy Statement which can be seen athttp://www.caterpillar.com/dataprivacy.

This Site allows you to search for, order and purchase certain Caterpillar (or its affiliates) products (“Product” or “Products”). The Site includes descriptions of the Products. If you want to determine Product availability and purchase the Product, you will be sent to customized pages (these pages, being a “Dealer e-site”) that provide specific information and pricing provided by authorized Caterpillar dealers (“Dealers”). Such pages provide Dealer-specific information based upon input and data provided by each individual Dealer, for example, www.catpeijian.cn/zh-CN/lshmnc. A Dealer’s privacy statement for its Dealer e-site describes how that Dealer collects, shares and otherwise processes personal information on its Dealer e-site. We encourage you to read each Dealer’s privacy statement for its respective Dealer e-site. The terms of sale (including the price) under which each Dealer sells Products to you are set independently by each such Dealer. This Site may also include links to Dealer websites, which are not Caterpillar websites. Caterpillar does not control, and does not have responsibility for the content, availability, operation or performance of the Dealer websites. Your usage of a Dealer’s website will be subject to the Dealer’s privacy policies. Caterpillar encourages you to read the posted Dealer’s privacy statement.

Part I What is personal information?

For purpose of this Privacy Notice, personal information is any information about a specific individual or information that identifies or may identify a specific individual. Examples of personal information that we may collect include, but are not limited to:

• Contact Information (e.g., name, address, telephone number, email address);

• Identification and Verification Information (e.g., photographs, ID cards, other proofs of identity);

• Billing Information (e.g., financial account data, invoices, receipts);

• Information to fulfill items such as, but not limited to, communications, contracts, purchase orders, payments, and receivables;

• Repair Information (e.g., repair needs and status);

• Warranty Information (e.g., purchase history, extended warranties);

• Customer Satisfaction Information;

• Client Relationship Management Information (e.g., information necessary to populate a customer’s profile or to facilitate marketing automation); and

• Other information required to comply with applicable laws, including valid search warrants, subpoenas, or court orders.

Part II Privacy Notice

This Privacy Notice will help you understand the following information:

1. How do we collect your personal information?

2. How do we use your personal information?

3. How do we use cookies?

4. How do we share and transfer your personal information?

5. How do we safeguard your personal information?

6. How long do we keep Personal Information?

7. How do we dispose of Personal Information?

8. How can you manage your personal information?

9. How do we process personal information of children?

10. How will this Privacy Notice be updated?

11. How to contact us

Section 1. How do we collect your Personal Information?

We collect personal information in a variety of contexts.

(1) Personal Information You Created or Provided to Us

We collect Personal Information that you voluntarily provide to this Site. For example, if you register your account on this Site or request additional information on a Product or place an order, you will be asked for information such as user’s name, company name, and e-mail address. When you search for a Product, you might also provide information relating to your or other’s equipment (e.g., machines, engines), equipment fleet or other business information. When you purchase a Product on this Site, you will be asked to provide phone number, address, payment information. Similarly, if you e-mail us through the “Contact Us” link, we will ask for the user’s name and e-mail address (you may choose to provide additional information as well) so that we can respond to your questions or comments.

(2) Personal Information We Collected Automatically

We automatically collect the following information when you use our products or services of this Site:

(i) When you use the Site or services provided by this Site, we automatically collect details of your use of our services and save them as relevant weblogs. For example, we may collect the content you are searching for, IP address, type of browser, telecom operator, language used, date and time of access and record of web page you visited, etc.

(ii) When you contact us, in order to verify your identity and help you solve the problem, we may record your conversations with us and collect other essential information necessary to solve the problem.

(iii) We link to third party solutions that enable third-party companies to collect certain information when you visit this Site. These companies use non-personally-identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, hardware/software information, cookie and session ID) and information that may allow for identifying you (e.g., static IP address) during your visits to this Site and other websites in order to provide advertisements for products likely to be of greater interest to you or advertising-related services, such as ad delivery, reporting, attribution, analytics, and market research. These third parties typically use a cookie, pixel tag, web beacon or other similar tracking technologies to collect this information. For example, in the course of visiting our site, these third parties may place or recognize a unique cookie on your browser in order to collect certain information about you and your interest in our Products and could be used to show you ads on other websites based on your interests. More information on these is available in our Cookie Statement (https://www.catpeijian.cn/zh-CN/ecim/cookies). An example is described below:

• Google’s Google Analytics - Google Analytics is a third party analytics service. We use Google Analytics to collect information about the use of this Site. Google Analytics collects information on visitor behavior on this Site such as how often users visit this Site, what pages they view when they do so, and what other websites they used prior to coming to this Site. We use the information we get from Google Analytics to analyze user behavior, improve Site performance, personalize the user experience, and analyze the effectiveness of our marketing campaigns. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. Google Analytics anonymizes the IP address before it is stored. We do not receive the non-anonymized IP address. We may combine the Google Analytics data with first and third-party data information which may include personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this Site, the cookie cannot be used by anyone but Google. To learn more about how Google collects and uses data, visit https://policies.google.com/privacy/partners. For opt-out options specific to Google Analytics, please visithttps://tools.google.com/dlpage/gaoptout.

(3) Your Information We Collect Indirectly

In order to confirm the transaction status and provide you with after-sale services, we will collect your transaction, payment and logistics information related to the transaction progress through dealers, payment agencies, logistics companies, etc. you select based on the transaction.

Caterpillar 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 of Caterpillar, and where you have consented for Caterpillar to do so.

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 applicable laws—it may be implied where the purpose is apparent from the circumstances and you voluntarily provide your personal information. There may be circumstances under which Caterpillar must obtain explicit consent from you. Such consent is your choice and is entirely voluntary. In some circumstances, you may withdraw your consent to Caterpillar’s collection and use of personal information subject to contractual and legal restrictions and reasonable notice.

Section 2. How do we use your Personal Information?

Caterpillar uses personal information in ways that are compatible with the purposes for which the information was originally collected. This may include use for a purpose that is reasonably related to the original purpose of collection. Caterpillar collects, uses, and discloses personal information as an essential part of operating this Site.

Caterpillar uses Personal Information to conduct business operations (e.g., satisfy customer orders), market new products through individual outreach or group communications (e.g., newsletters), assess internal performance, manage customer relationships, (e.g., invoicing and payments), manage risk and compliance, and support various administrative functions.

Personal information may also be processed in order to meet legal requirements applicable to Caterpillar, such as filing with government agencies, complying with lawful orders to provide information, meeting contractual commitments, and in connection with Caterpillar safeguarding its rights and property.

Below, we describe some examples of how Caterpillar may use the personal information collected:

Examples of Personal Information	Examples of Use
Individual Contact Information (e.g., name, address, telephone number).	To communicate with you and to provide you with the products or services.
Your browsing and search preferences.	To improve our products or services and provide you with information and services more in line with your personalized needs.
Billing Information (e.g., invoices, receipts).	To complete customer orders and submit necessary billing information.
Identification and Verification Information (e.g., WeChat account, phone number, other proofs of identity).	To enable access to the Site

Section 3. How do we use cookies?

(1) Cookies

This Site uses cookies and other tracking technologies as described above and in our Cookie Statement (https://www.catpeijian.cn/zh-CN/cat/privacy).

(2) Do Not Track

Most web browsers have the “Do Not Track” feature, which sends a “Do Not Track” request to the website. So far, this Site will not respond to Do Not Track requests that may be published by your browser. Major internet standards organizations have not yet established rules on how websites shall respond to such requests. We will make appropriate adjustments according to the issuance of relevant standards.

Section 4. How do we share and transfer your Personal Information？

Because Caterpillar operates a global business, we may need to transfer your personal information to different jurisdictions for our business purposes. Caterpillar may transfer personal information to countries or jurisdictions that may not legally mandate the same level of data protection as the jurisdiction in which that personal information was collected. This Privacy Notice applies to all Caterpillar operations and their data processing activities and Caterpillar has entered into data transfer agreements with its affiliates worldwide to protect personal information.

Caterpillar only shares personal information with others in a manner consistent with this Privacy Notice, for the purposes stated above, when required by law, or with your consent. Information transfers to third parties will generally be transfers to third-party processors for those purposes consistent with this Privacy Notice. In addition, Caterpillar may transfer personal information to third-party data controllers as required by law, with your consent, or with approval from a relevant authority. We also share your personal information with our Dealers or other business partners in a manner consistent with this Privacy Notice. In some jurisdictions, transfer of specifically delineated categories of data or transfer to certain third parties may require explicit consent from you. In all instances, the transfer of personal information is subject to applicable law and Caterpillar’s Global Data Privacy Statement including its appendices (available at http://www.caterpillar.com/dataprivacy).

When Caterpillar shares personal information with third parties that process the personal information on Caterpillar’s behalf (e.g., contractors, consultants), Caterpillar takes reasonable steps to require such recipients to protect personal information in accordance with applicable laws. Examples of third parties with whom we may share information for any of these purposes include:

• Vendors, service providers, and other partners who support our business, such as providing technical infrastructure services;

• Law enforcement or other government agencies (when required by law; authorized by the customer; to protect Caterpillar, a person or property; and to support our business, such as in applications for government grants);

• Subsidiaries, affiliates and other entities controlled by Caterpillar;

• Other third-party service providers that process personal information on behalf of Caterpillar; and

• An acquiring entity (or an entity that is interested in acquiring) in the event that Caterpillar divests (or is considering divesting) a portion of its business.

By using the Sites or services on the Site, you fully understand and consent to the transfer of your Personal Information by Caterpillar globally for the above purposes in a manner consistent with this Privacy Notice.

Please note, under the applicable law, if we take technical measures and other necessary measures to process Personal Information so that the data recipient cannot re-identify a specific individual, we can share, transfer or publicly disclose such processed data without further notice to you or your consent.

Section 5. How do we safeguard your Personal Information?

We utilize reasonable measures, including information technology security and physical security measures, to protect Personal Information. These measures are appropriate to the risks posed by the processing of Personal Information and to the sensitivity of the Personal Information, and take into account the requirements of applicable law. We require all persons to abide by applicable security policies related to Personal Information when using the Site.

If you find that your Personal Information, especially your account or password, has been leaked, please contact us immediately according to the contact information listed in the first part of this Privacy Notice, so that we can take appropriate measures according to your application.

Section 6. How long do we keep Personal Information?

We store Personal Information as needed to accomplish the purposes identified above and to meet legal requirements, including record retention. Our retention of your personal information is at all times subject to the applicable law. This storage period may extend beyond the term of your relationship with Caterpillar.

Section 7. How do we dispose of Personal Information?

When Personal Information is no longer useful, or in any event, after legal authority to retain it has expired, personal information will be destroyed, in accordance with the applicable law and pursuant to procedures established by the relevant Caterpillar system or process.

Section 8. How can you manage your Personal Information?

Caterpillar takes steps to maintain the accuracy and completeness of personal information. You may request and receive reasonable access to the personal information you have provided to Caterpillar and have an opportunity to correct it if necessary. Caterpillar procedures grant you reasonable access to your personal information and enable the exercise of other rights that may be available to you under applicable law.

Unless prohibited by applicable law or, in some cases, as mandated by applicable law, your right to access your personal information may be limited. Examples for why your access may be limited include:

• The request relates to legal advice and proceedings;

• A legal privilege may be claimed regarding the subject matter of the information;

• The personal information also includes the personal information of a third party who has not consented to disclosure and whose privacy would be affected by any such disclosure;

• The request is insufficiently detailed or has already been responded to; or

• The request is frivolous or vexatious; or

• The information could include confidential information.

You can access and manage your Personal Information through the following ways:

• If you want to access or edit the personal data in your account and payment information, change your passcode, add security information or close your account, you can perform such operations directly by logging into your account.

• You may also send emails to CATPEIJIAN@cat.com at any time to cancel your account, withdraw your consent, or to request to unsubscribe from any commercial emails we send to you.

Please note that

• After you have withdrawn your consent, we will not process the corresponding Personal Information any more for the purposes for which you had consented.But your decision to withdraw your consent does not affect the previous processing of Personal Information based on your authority.

• After your account has been canceled, we will cease providing you with products or services, and delete your Personal Information upon your request, unless otherwise stipulated by laws and regulations.

Section 9. How do we process Personal Information of children?

Our products, website and services are designed for adults.No child is allowed to create a user account by himself or herself. By using the the Site, you represent that you are not less than 18 years of age.

Section 10. How will this Privacy Notice be updated?

We reserve the right to amend this Privacy Notice as needed. When we do, we will note near the top of this Privacy Notice the date that any such changes are made and/or when they become effective. In some instances, if the changes we make are material, we may also send you an e-mail message or other communication telling you about such changes and any choices you may have or actions you can take before they go into effect. Depending on the nature of the changes and subject to applicable law, your continued relationship with Caterpillar will demonstrate your acceptance of those changes.

Section 11. How to Contact Us

If you have any concerns, opinions or advices on the Privacy Notice, you may contact us by sending an email to CATPEIJIAN@cat.com.