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KOMATSU MACHINE OPERATOR PRIVACY POLICY
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pictures, videos and sound recordings
4. Why is your personal data processed?
When you use Komatsu machines equipped with MMS, your personal data are processed for the following rea-
sons:
(a) Safety and security
(b) Warranty
(c) Misuse and theft prevention
(d) To provide training and develop training materials
(e) To improve machine and operational efficiency
(f) To improve jobsite safety and efficiency
(g) To provide faster and more tailored support service
(h) To optimize jobsite layout, machine resource allocation and driving routes
(i) For real-time jobsite monitoring and management
(j) Where applicable: to follow-up on rental agreements
(k) To improve MMS and associated services
(l) To evaluate, analyse and report on machine usage
(m) To comply with a legitimate request from law enforcement or other authorities
We may also process your personal data to inform a third party in the context of a possible merger with, acquisi-
tion from/by or demerger by that third party, even if that third party is located outside of the EU.
Please note that your employer can also use MMS to process data to evaluate your performance as employee
as well as for other purposes, but this is entirely between you and your employer.
5. What makes the processing of your personal data legitimate?
The data protection laws require us to precisely indicate to you which legal option we rely on to make the proc-
essing of your personal data legitimate. We need to clarify this for each of the purposes listed in section 4
above.
For the purposes (a) to (l) as indicated in section 4 above as well as for the purpose of informing a third party in
the context of a possible merger, acquisition or demerger, the processing of your personal data is necessary for
our legitimate interests, which in this case concern:
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ensuring the safe and secure deployment of the machines
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preventing misuse and theft
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commercial interests which include handling warranties, the need to be able to improve MMS, our ma-
chines and services and training materials and the need to be able to enter into corporate transactions.
For purpose (m) we need to process your personal data to comply with our legal obligations.
6. Recipients and transfers
Your personal data may be sent to the following categories of recipients:
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yourself
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your employer or business relations
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companies within the Komatsu group of companies, including our affiliates, as well as our service providers
who help us to provide MMS
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governmental, judicial and other competent bodies in case of a justified yet legally binding request
Your personal data are transferred to Japan, for which model contract clauses on the basis of European Com-
mission decision 2004/915/EC have been put in place between Komatsu and Komatsu Europe.
For more information, please address your questions to PrivacyOffice@komatsu.eu
7. How long will your personal data be stored?
Your personal data are only processed for as long as needed to achieve the purposes listed in section 4 above.
We will de-identify your personal data when they are no longer necessary for the purposes outlined in the pur-
pose for processing, unless there is:
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