Privacy of User Information on the Service

This notice has been prepared to notify you of the fact that your data, which were previously in Hyundai Construction Equipment (“Company” or “We” or “HCE”)’s possession either through direct collection, collection through device provided and/or developed by Company.

The Company keeps and processes information about contact persons at our customers, suppliers, vendors and/or business partners. This notice describes how we collect and use information (including personal data) about you during and after your business relationship with us, in accordance with applicable law.

Please note that processing of your information as set forth in this notice is necessary for us to enter into and maintain our business relationship with you.

Please regularly review this notice carefully to understand about your information.

DATA PROTECTION PRINCIPLES

We will comply with data protection law or any other applicable regulation. This says that the 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.

THE KIND OF INFORMATION WE HOLD ABOUT YOU

We may collect, store, and use certain categories of information about you, such as:
♦ Personal contact details: Name, Log-in ID, Log-in password, email address, mobile phone number, home phone number, machine number, RMCU modem number, home address
♦ System Data: Electronic Data including fault alerts, engine data, and physical location.

HOW YOUR INFORMATION IS COLLECTED

We may collect your information directly from you or through devices. We may also collect information automatically from you.

HOW WE WILL USE INFORMATION ABOUT YOU

We will only use your information in compliance with applicable law and regulation. Most commonly, we will use your information in the following purposes:
♦ Communicating with you or the customer about products and services
♦ Performing campaigns or other service activities
♦ Planning, performing and managing the (contractual) relationship with you or the customer
♦ Ensuring compliance with legal obligations such as record keeping obligations
♦ Solving disputes, enforce our contractual agreements and to establish, exercise or defend legal claims

We will use your information in the following legal bases:
1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

DATA SHARING

We may share your data with third parties, including HCE’s affiliates and third-party service providers, in or outside the EU to comply with our legal or contractual requirements and to pursue our legitimate interests in connection with our relationship. If such a recipient is located outside of the European Union and the European Economic Area (“EEA”) in a country that is not recognized by the European Commission as ensuring an adequate level of data protection, we will implement appropriate measures to ensure that your information remains protected and secure when it is transferred outside of your home country, in accordance with applicable data protection and privacy laws. These measures include data transfer agreements implementing European Commission's Standard Contractual Clauses (a form of data transfer agreement pre-approved by the European Commission as providing adequate safeguards for data).

DATA SECURITY

We have put in place appropriate security measures to prevent your information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your information on our instructions and they are subject to a duty of confidentiality. 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.

DATA RETENTION

We will only retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying its contractual obligations or any other legal issue. To determine the appropriate retention period for information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements. Broadly, most of your information is kept for the duration of our working relationship with you.
In the following circumstances, your information will be retained for longer than the specified periods:
A. as required by law or court order.
B. as needed to defend or pursue legal claims.

In certain circumstances we may anonymize your information so that it can no longer be associated with you, in which case we will use such information without further notice to you.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Updating your data
It is important that the information we hold about you is accurate and current. Please keep us informed if your information changes during your working relationship with us.

Your rights in connection with information under certain circumstances, by law you have the right to:
♦ Request access to your information. This enables you to receive a copy of the information we hold about you and to check that we are lawfully processing it.
♦ Request correction and/or deletion of the information.
♦ Request the restriction of the processing of your information.
♦ Request the object to that processing (especially if we use information for direct marketing, you can “opt out” at any time)
♦ Request receipt or transmission to another organization, in a machine-readable form, of the information that you have provided to us

We will 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 information is not disclosed to any person who has no right to receive it.
In the event that you wish to make a complaint about how we process your information, please contact privacy@hyundai-ce.com and we will endeavor to deal with your request as soon as possible. You have also the right to complain directly to the relevant data protection authority.

ENQURIES ABOUT THIS NOTICE

If you have any questions about this notice or how we handle your information, please contact privacy@hyundai-ce.com.

CHANGES TO THIS NOTICE

We reserve the right to update this notice at any time without prior notice, and we will notify you when we make any material updates.