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JW BELL PRIVACY STATEMENT

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JW Bell Co. respects the privacy of its clients, manufacturers, and other third parties. This Privacy Statement describes the practices of JW Bell for collecting, storing and using the information we may collect from you (“you”, “your” or “Client”) or that you may provide to us from time to time on purchase agreements, rental agreements, service agreements and other business documents, including but not limited to information regarding machines, equipment or products when you visit our website or related websites when you email or contact us.

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Please read this Privacy Statement carefully to understand our policies and practices regarding your information. By using our website or providing us with information, you agree to this Privacy Statement.  This Privacy Statement will be updated periodically, so please be sure to reread it from time to time. 

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1. What Information We May Collect

The information we collect may include, but is not limited to, your search queries on our website, personally identifiable information such as your name, address, e-mail address and other contact information, information that you provide when entering a contest or promotion sponsored by us, information that you provide when you report a problem, records of emails and other correspondence that you send to us, your responses to surveys that we might ask you to complete, and details of your transactions with us.

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To use certain portions of our website, you may need to provide us with personal information. In these situations, if you choose not to provide that information, it may not be possible for you to gain access to parts of the website or for us to respond to you or provide services.

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(a)  System Data

System data is information that is transmitted to us through Web applications (“Applications”) including, but not limited to, similar devices (“Devices”). We use the term “Digital Offerings” to refer collectively to all Applications and Devices that we use, which may include, but is not limited to:

• (i) 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.

• (ii) 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 Client and Asset and communication channel used by a Device.

• (iii) Inspection Data, including results of inspections using a JW Bellor third-party inspection system.

• (iv) Device Location Information, including the physical location of an Asset (e.g., determined using satellite, GPS, cell phone tower, Bluetooth or WiFi signals).

• (v) Fluid Data, including analysis results of fluid samples (such as oil, hydraulic and coolant fluids) obtained using JW Bell or third-party tools.

• (vi) Event Recorder Data, including location, speed, direction, and associated video recordings, use of controls and positive train control information.

• (vii) Service and Maintenance History, including work orders (records of all maintenance, repairs, parts purchases, replacements and modifications to an Asset), component life (history of usage and wear life of a component), maintenance schedules, 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 manufacturers to correct a known problem with an Asset).

• (viii) Site and Environmental Conditions, including the type of work being done, condition of roads or tracks, altitude, climate, and material tracking.

• (ix) Patterns of Use, including any user-defined information relating to a product you provide to us through a Digital Offering.
   

(b) Operations Data

Operations Data may include:

• (i) Information contained in invoices, purchase orders, sales contracts, service contracts, e-forms and other transactional documentation generated as part of the business relationship between us.

• (ii) The Client’s name, address, industry, client category, and the name, position, email address, and telephone number of the Client’s designated contact person.

• (iii) Work order data, including information about the Client, Asset involved, problems identified, and repairs performed, emissions data, fuel usage, service meter hours, software and hardware version numbers and installed attachments.

• (iv) Information relating to Client parts and machine purchases, returns and replacements.
   

(c) Payment Information

Payment Information may include your banking account details, debit card details, credit card details, credit card type (i.e. Visa, Mastercard, American Express), your billing address associated with the credit card, your shipping address and other information that is required to process the payments.

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(d) Personal Information

“Personal Information” is information that relates to an identified or identifiable individual, which may include, but is not limited to: name; postal address (including billing and shipping addresses); telephone number; email address; identification information such as usernames and user IDs; the employer or company with which an individual is associated and his or her role and title; User Profile information; geo-location information; information about any computer or mobile Device with which you access Applications.

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Information collected by us may simultaneously constitute System Data, Personal Information, and Operations Data, or any combination thereof. Depending on the applicable local law, some Personal Information collected may be considered “Sensitive Personal Information” (i.e., Personal Information subject to additional protections).

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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), tax identification, and diversity classification.

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We may use anonymized (or de-identified information), that was derived from Personal Information, but in its anonymized form cannot be identified with a specific individual. This de-identified information is not considered Personal Information for purposes of this Privacy Statement and is not covered by this Privacy Statement. However, if such information is used or formatted in such a way that it is possible for that information to be identified with a specific individual, then it will be considered Personal Information as appropriate.

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How We Collect Information.

We collect information in a variety of ways. For example, we collect information that you provide to us through various contacts, the information we collect through your use of our products or services, and information we collect from publicly available sources or third parties.

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(a) Information You Provide to Us

We collect the information you give us when you engage with us and/or use our products or services. For example, we may collect information when you interact with us, attend one of our stands at a trade show, make an inquiry, place an order, or contact our customer service.

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(b) Information Collected Through Your Use of Our Products and/or Services

In addition to the information you provide to us directly, we may collect information through the use of our products and/or services. For example:

• (i) Through Applications / Devices: We may receive information directly via cellular or satellite link, or radio or Ethernet connection from Assets equipped with an Application or a Device that was either pre-installed or installed by us.
   

(c) Information from Third-Party Sources

We may collect information from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from you.
 

(d)  Other Ways We Collect Information

As you navigate through our website, we may use automatic data collection technologies to collect certain information about your browsing actions and patterns, the number of times your visit our website, and information about your computer and internet connection, including your IP address, operating system and browser type. The technologies we use for this automatic data collection may include cookies. A cookie is a small data file placed on the hard drive of your computer, which enables us to recognize you and helps us to personalize your visits to our website.

We use Cookies to:

• Estimate audience size and usage patterns;

• Understand and save your preferences for future visits, allowing us to customize the Site and Services to your individual needs;

• Advertise new content and services that relate to your interests;

• Keep track of advertisements and search engine results;

• Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and

• Recognize when you return to the Site.
   

We set some Cookies ourselves and others are set by service providers.  We use Cookies set by service providers to provide us with useful information to help us improve our Site and Services, to conduct advertising, and to analyze the effectiveness of advertising.

Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies.  If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Site.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org.

You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our website. 
 

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc.  Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Site and Services, compile reports on their activity, and provide other services related to their activity and usage.  The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website.  The technologies used by Google Analytics do not gather the information that personally identifies you.  The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies.  
 

How We May Use Information.

We use the information that we collect and that you provide to us for a variety of business purposes, including, but not limited to, providing you with products and services that you request from us, carrying out our obligations and enforcing our rights under our agreements with you, data analytics, marketing purposes, improving our products and services, and notifying you about additional products or services that may be of interest to you. We do not sell or rent your information.
 

(a) To Provide Services to You and Others:

• (i) To allow you to monitor the status of Assets, to complete and fulfill orders, and to communicate with you regarding your purchase or rental of Assets and your purchase of Asset parts and provide you with related customer service.

• (ii) To fulfill Client support agreements, perform maintenance and repairs and deliver rental Assets or parts.

• (iii) To make recommendations regarding safety, Asset health, maintenance, worksite efficiency and productivity training for operators.

• (iv) To enhance the safety of machine operations, including by tracking proximity to Assets, other objects or humans.

• (v) To enable remote technician services, such as remote troubleshooting, and remote tuning.

• (vi) To provide you with location-based services and content.

• (vii) To process payment related to our products and services.
   

(b) To Enable Communications:

• (i) To send administrative or contractual information, for example, information regarding our terms and conditions of sale and rent and of using Digital Offerings, warranty policies or service contracts.

• (ii) 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 which you may opt-out at any time.
   

(c) For Other General Business Purposes:

• (i) To conduct market research.

• (ii) To perform data analytics, audits, improve products, develop new products, enhance, improve or modify our Digital Offerings, identify usage trends and operate and expand our business activities and for statistical analysis based on aggregated and de-identified data, such as benchmarking reports.

• (iii) To provide services to Clients, manage workflow, monitor repairs, project future maintenance and service, and troubleshoot issues.

• (iv) To validate the effectiveness of recommendations, resolve complaints, and fulfil orders.

• (v) To manage Assets and parts inventory in order to provide you with machines, parts and services.

• (vi) To manage a fleet of owned or rented Assets.

• (vii) To maximize the efficiency of operations and increase sales.

• (viii) To develop digital Applications.

• (ix) To manage your account with us and generally keep our records up to date and administer our relationship with you.

(d) Other Uses:

• (i) To allow you to participate in sweepstakes, competitions 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 information, including Personal Information. We suggest that you read any such rules carefully.

• (ii) For additional uses as agreed by you and us, which may, for example, arise from new types of products or services that we may offer you.
  
  How We Store and Protect Information

We have implemented reasonable measures to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. However, the transmission of information is not completely secure. We cannot guarantee the security of Personal Information transmitted to us, and any transmission of such information is at your own risk. Our website may contain links to third-party websites and online services. We are not responsible for the privacy practices or content of third-party websites. We retain Personal Information collected from you as long as your account is active or otherwise as long as we need to fulfil the purposes for which it was collected unless otherwise required by law.

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Information We May Share with Third Parties

We may disclose Personal Information that we collect or that you provide to our parent, subsidiary and affiliated entities, to our manufacturers and their subsidiaries and affiliates, and to contractors, service providers and other third parties used to support our business and the business of our manufacturers. We also may disclose such information if required by law, to enforce our rights or if we have a good faith belief that such disclosure is necessary or appropriate to protect the rights, property, or safety of JW Bell, our clients or others. Additionally, any Personal Information that you provide may be transferred in a merger, acquisition, restructuring, or other corporate transaction involving JW Bell or its Assets.  
 

Children

We do not want to collect or maintain information from those under the age of 16. No part of our website is structured to attract anyone under the age of 16. By using our website you represent that you are not less than 16 years of age.
 

Access, Changes and Corrections

Subject to certain exceptions prescribed by law, you have a right to access or request correction or deletion of most personal data that we have about you. In some circumstances, it may not be possible for us to provide you with all of your personal data. For instance, there may be instances where disclosing the requested information would impact the privacy of another individual. Where we cannot provide access to personal data held about you, we will tell you why.

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If you think that any personal data we hold about you is inaccurate, you may contact us using the contact details below and we will take reasonable steps to ensure that the information is corrected. We may take steps to verify your identity before providing you access to your personal data.

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If you send any request for access to or correction of your personal data, we will do our best to respond within a reasonable period after your request. We may retain all information you submit for backups, archiving, prevention of fraud, legal compliance or where we have a legitimate reason to do so.

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International Transfer

If you are accessing the website from outside the United States, you are sending information, including Personal Information to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside your country of residence. These countries may not necessarily have data protection laws as comprehensive as those in your country. The information transferred to the United States or another country is subject to the laws of that country and may be disclosed or accessed in accordance with those laws. By transferring information or allowing information to be transferred to us, you consent to the transfer, processing and storage in countries outside your country of residence. 

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Do Not Track’ notifications

Some browsers allow you to automatically notify websites you visit not to track you using a “Do Not Track” signal. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.

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Contact Information

This Privacy Statement may change from time to time, so please check the Privacy Statement periodically for updates.  To (i) ask questions about this Privacy Statement or our privacy practices; (ii) to obtain a copy of this Privacy Statement in paper format; (iii) request access to information that we have about you; or (iv) correct any information you have provided,

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