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FOREWORD
KOMATSU MACHINE OPERATOR PRIVACY POLICY
This Privacy Policy governs the processing of personal data which takes place when operators based in the Eu-
ropean Economic Area or EEA (which consists of the EU, Norway, Liechtenstein or Iceland) operate Komatsu
machines equipped with Machine Monitoring Systems such as KOMTRAX, KOMTRAX Plus, K-plus 2, iMC or
Smart Construction Cloud system (hereinafter together referred to as "Machine Monitoring Systems" or "MMS"),
i.e. systems that allow the wireless monitoring of Komatsu machines.
The MMS are globally managed and maintained by Komatsu Limited, a Japanese corporation having its princi-
pal place of business at no. 3-6, Akasaka 2-Chome, Minato-Ku, Tokyo, Japan ("Komatsu"). MMS are made
available in the EEA by Komatsu Europe International NV, a corporation organised and existing under the laws
of Belgium, with registered office at 1800 Vilvoorde, Belgium, Mechelsesteenweg 586, registered in Brussels un-
der number RPR/CER(0)404.968.268 ("Komatsu Europe", together with the other Komatsu subsidiaries in the
EEA referred to as "we" or "us"). Komatsu Europe acts as Komatsu's representative in the EU with respect to
MMS.
1. Who is responsible?
Komatsu, Komatsu Europe, Komatsu distributors and dealers, as well as the owner of the machine and your
employer (when your employer is not the owner) are all responsible for the processing of your personal data
through MMS.
2. How are responsibilities allocated?
To arrange for the aforementioned shared responsibility, Komatsu, Komatsu Europe, the distributors, dealers,
owners and your employer have put in place contractual arrangements between them which govern this shared
responsibility.
The essence of these arrangements is that you can always direct your questions and requests regarding
the processing of your personal data (i.e. storage, collection, transfer etc. of all information that relates to you as
operator) to the party with whom you have most direct relationship.
In principle this means that you should first and foremost refer to your employer (if you are an employee) or
your customer (if you are an independent contractor). Komatsu, Komatsu Europe, Komatsu distributors and
dealers, as well as the owner of the machine and your employer/customer (if he is not the owner) will liaise be-
tween each other to ensure that your questions, requests and rights regarding the processing of your personal
data are given due regard.
To be clear:
•
For staff members of Komatsu Europe or of other Komatsu subsidiaries in the EEA, the request can be di-
rected directly to Komatsu Europe by sending an e-mail to PrivacyOffice@komatsu.eu
•
For staff members or independent contractors of a distributor, a dealer or an owner, meaning you either
work for or on behalf of a distributor, a dealer or an owner, you are to contact the distributor, the dealer or
the owner with your questions or requests.
•
For staff members or independent contractors of another entity than the ones referred to above, you are to
contact first and foremost your employer or customer.
If you are unsure who to contact, please send an e-mail to Komatsu Europe at PrivacyOffice@komatsu.eu stat-
ing your full name, function title and entity you work for, and we will refer your request to the appropriate respon-
sible party.
3. What sort of personal data is processed?
When you use a machine equipped with MMS, the following types of personal data are collected and process-
ed:
•
personal identification data (e.g. names)
•
current employment (e.g. function title and employer details)
•
details regarding:
•
your use and operation of the machine
•
machine location and position
•
usage times and statistics
•
error codes and frequency of those codes
KOMATSU MACHINE OPERATOR PRIVACY POLICY
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