Data Policy

This Data Management Statement describes the practices of ME Elecmetal S.A. and the companies belonging to its Group, for collecting, storing, and using information about our customers ("Customers," "you," or "your"), including, but not limited to: personal data, financial data, and data related both to ME Elecmetal products and services and those that are not, as well as attachments and other assets unrelated to ME Elecmetal operated by or on behalf of the Customers ("Assets").

You should regularly review this Statement to understand what information we collect and what we do with it. By providing us with System Data, Operations Data, or Personal Information (each as defined below) (collectively called "Data"), you agree to the terms and conditions of this Data Management Statement, including our collection, use, and distribution of such information, as set forth in this Statement.

1. What Information We Collect

We may collect the following information:

1. a) System Data

System data consists of information transmitted to us through digital platforms (“Platforms”), OKC, VisionLink, ProductLink, and similar applications ("Applications") and via telematics (and similar devices) ("Devices") (we use the term "Digital Offerings" to collectively refer to all the applications and devices we use), which may include:

Information about devices, assets, and components, including model number, serial number, order number, software and hardware version numbers, as well as performance and configuration, including work tools or other peripheral devices connected to the assets.

Electronic data, including sensor logs, trends, histograms, event data, other alerts, digital status data, fault codes, downtime, daily and cumulative fuel consumption, emissions data, service meter hours and readings, electronic data files downloaded from an asset either manually or automatically, troubleshooting data, and other data depending on the Customer and the Asset and the communication channel used by a device.

Inspection data, including inspection results obtained through the use of a ME Elecmetal or third-party inspection system.

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

Event recorder data, including location, speed, direction, and associated video recordings, as well as control usage and positive train control information.

Maintenance and service history, including work orders (records of all maintenance, repairs, parts purchases, replacement, and modification of an asset), component life (usage and duration history of a component), maintenance schedule, planned maintenance, warranty coverage data, maintenance and repair contracts, service intervals (scheduled interval for planned maintenance of component replacement activities of an Asset), component lists (parts lists that make up an Asset), and service letters (description of special service actions recommended by manufacturers to correct a known problem with an Asset).

Usage patterns, including any user-defined information related to a product that you provide to us through a Digital Offering.

1. b) Operations Data

Operations Data may include:

Information contained in bids, invoices, purchase orders, sales contracts, service contracts, electronic forms, and other transactional documentation generated as part of the business relationship between us.

The name, address, industry, Customer category, as well as the name, position, email address, and phone number of the Customer's designated contact person.

Work order data, including Customer information, as well as the involved asset, identified problem, and repairs performed.

Information related to Customer parts, as well as their purchases, returns, and machine replacements.

1. c) Personal Information

Personal information is information related to an identified or identifiable person, including, but not limited to:

Name

Postal address (including billing and shipping addresses)

Phone number

Email address

Identification information, such as username and user ID

The employer or company associated with an individual, as well as their position and title

User profile information

Geolocation information

Information about any computer or mobile device you use to access applications

Information about your use of the applications

Audiovisual data

Physiological data, such as eye movement, facial expression, and heart rate

The information we collect may simultaneously include system data, personal information, and operations data, or any combination thereof.

2. How We May Collect Your Information

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

1. a) Information You Provide to Us

We collect the information you provide 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 booths at a trade show, make an inquiry, place an order, or contact our Customer Service.

1. b) Information Collected Through the Use of Our Products and/or Services

In addition to the information you provide for direct use, we may collect information about your use of our products and/or services. For example:

Via Platforms/Applications/Devices: we may receive information directly via satellite or cellular connection, or Ethernet or radio connection from Assets equipped with an Application or Device we have pre-installed or installed, which may include System Data or Personal Information. We may also receive information through your use of our single sign-on services, which allow us to use your meconnect.com credentials to verify your identity and offer you the option to share some of your personal data with us.

Through wearable technology: we may collect information via wearable technology such as fatigue monitoring devices or radio-frequency identification tags embedded in helmets or safety vests.

1. c) Information from Third-Party Sources

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

Through ME Elecmetal S.A. or its contractors or affiliated companies: we may receive information from Elecmetal or its contractors or affiliated companies that have collected information about you through: (i) a satellite or cellular connection, or Ethernet or radio connection from Assets, which may include System Data (such as information related to the Device or Asset) or Personal Information (such as information generated by fatigue monitoring devices, cameras embedded in other devices or media, as well as proximity detection systems, and in-cab monitoring technology); or (ii) Digital Offerings.

From component manufacturers and OEMs (original equipment manufacturers): we may obtain system data from component manufacturers in your Assets. This information may be provided to us automatically.

From Asset owners and third parties: we may receive additional information from Asset owners, as well as operators and third parties responsible for managing an Asset.

From other sources: we may receive information about you from other sources, such as credit reporting agencies, public databases, marketing partners, the internet, social media platforms (including from people you are friends with or otherwise connected to), and other third parties. We may collect or generate information from troubleshooting data, your service providers (such as fluid analysts and site inspectors), or maintenance, inspection, or warranty records.

1. d) Other Ways We Collect Information

We may also collect other information about you, your device, or your use of the services in the ways described at the time of collection, or otherwise with your consent. You may choose not to provide certain information, but doing so may affect your ability to use some of the products and services.

3. How We May Use Your Information

We may use the collected information for the following purposes:

1. a) To Provide Services to You and Others:

To enable you to monitor the status of Assets, complete and fulfill orders, and to communicate with you regarding your purchase or rental of Assets, as well as related parts purchases, and to provide related Customer Service.

To fulfill Customer support agreements, perform maintenance and repairs, and deliver rental Assets or parts.

To make recommendations related to safety, Asset health, as well as maintenance, workplace efficiency, and productivity training for operators.

To improve machine operation safety, including proximity tracking to Assets, other objects, or humans.

To enable remote technician services, such as remote troubleshooting and remote tuning.

To provide location-based services and content.

To process payment related to our products and services.

1. b) To Enable Communications:

To send administrative or contractual information, for example, information related to our terms and conditions of sale and rental, and use of Digital Offerings, as well as warranty policies or service contracts; and all matters related to debt collection.

To provide you with information about new products and services; and to send marketing communications we believe will be of interest to you, which you may opt out of receiving at any time.

1. c) For Other General Business Purposes:

To conduct market research.

To perform data analysis, audits, improve products, develop new products; improve, fine-tune, or modify our Digital Offerings, identify usage trends, operate and expand our business activities, and for statistical analysis based on aggregated and anonymized data, such as benchmarking reports.

To provide services to Customers, manage workflow, monitor repairs, forecast maintenance and future service, and troubleshoot.

To validate the effectiveness of recommendations, resolve complaints, and fulfill orders.

To manage inventory of assets and parts to provide you with machines, parts, and services.

To manage a fleet of owned or rented assets.

To maximize operational efficiency and increase sales.

To develop digital applications.

To manage your account with us, and generally maintain our records and manage our relationship with you.

1. d) Other Uses:

To allow you to participate in sweepstakes, contests, or similar promotions, and to administer these activities. Some of these activities have additional rules, which may contain further information about how we use and disclose your information, including your Personal Information. We suggest you carefully read those rules.

For additional uses as agreed between you and us, which may, for example, arise from new types of products or services we may offer you.

Regarding audiovisual data that identifies individual or physiological data of an identifiable person, we will use such data only to provide products and services to our Customers, including recommendations on safety, Asset health, maintenance, workplace efficiency, and operator productivity training, as well as to improve our products and services.

4. How We May Disclose Your Information

Except as described in this Data Management Statement, we will not give your Personal Information to any third party without your consent. However, we may share or disclose anonymized information that reasonably cannot be used by third parties to identify you. We may also disclose information to:

Our business partners, including ME Elecmetal S.A. and its contractors or affiliated companies, to help us: (i) deliver to you the products and services you have requested. Our affiliates, to help us deliver to you the products and services you have requested.

Asset owners, to allow them to manage the use of the Asset they own.

Our service providers, who provide services such as tire replacement, fire suppression systems, engine packing, data analysis, information technology and related infrastructure provision, as well as application development, platform hosting, Customer Service, product development and auditing, consulting, and other services. Our service providers will receive the information they need to perform their designated functions and are not authorized to use or disclose the information for any other purpose.

Component manufacturers, to allow them to study the use of the products they have and improve those products and develop new ones.

Agents, service providers, and other third parties contracted or involved in business activities with Asset owners, who have responsibility for managing the Asset.

Third-party external service providers working with us who provide subcontracted services related to maintenance, repair, or modification of Assets.

Third parties involved in the event of a reorganization, merger, sale, business partnership, assignment, transfer, or other disposition of all or part of our business, as well as assets or shares (including anything related to any bankruptcy or similar proceeding).

Additional recipients as agreed between you and us.

When your information is disclosed to third parties, such as ME Elecmetal S.A. and its contractors or affiliated companies, your information will be subject to the terms of use, privacy policies, and/or data management statements of the respective third party.

We may also transfer and disclose your information to third parties to comply with a legal obligation, including the following cases:

Disclose information to a related third party in the event of a reorganization, merger, sale, business partnership, assignment, transfer, or other disposition of all or part of our business, as well as assets or shares (including anything related to any bankruptcy or similar proceeding).

Disclose information to additional recipients as agreed between you and us.

Disclose information when there is a legal investigation by regulatory authorities or self-regulatory organizations;

If a mandate, order, or other judicial instrument requires us to disclose personal information, which may include legal access by Canadian, British, Chilean, U.S., or other foreign government authorities, as well as courts or law enforcement agencies;

Disclose information to protect our assets or when necessary for the establishment, exercise, or defense of legal claims;

Disclose information to other organizations investigating a breach of an agreement or violation of the law;

When necessary for the detection, prevention, and suppression of fraud and other criminal activities, as well as other matters of public interest;

When necessary to protect our employees, Customers, and others; and

In situations permitted or required by Canadian, British, Chilean, U.S., or any other applicable laws.

5. International Transfers

Your data may be stored and processed by us, our affiliates, and our service providers in jurisdictions that do not have data protection standards or other laws as strict as those in the country where you reside. If information is transferred to another country or foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed or accessed by courts, law enforcement, and government authorities as provided by the laws of that jurisdiction. By transferring Data or allowing Data to be transferred to us, you agree to the transfer, processing, and storage of such Data in countries outside the nation in which you reside, as described in this Data Management Statement.

6. Security

We have implemented reasonable organizational, technical, and administrative measures designed to protect information within our organization. Unfortunately, it is not possible to guarantee that any data transmission or storage system is 100% secure. If you have reason to believe your interaction with us is no longer secure (for example, if you believe your account security has been compromised), please notify us immediately as set forth in the "Contact" section below.

7. Change, Correct, or Access Personal Information

Subject to certain exceptions established by law, you have the right to request, correct, and access most of the personal data we have about you. In some circumstances, we may not provide you with all your personal data. For example, if disclosing the requested information would affect another person's privacy. If we cannot provide you access to the personal data we have about you, we will tell you why.

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

If you submit any request to access or correct your personal data, we will make our best effort to respond within a reasonable period after such request.

8. Electronic Communications

With your consent, we may use personal data to inform you about products or services we have available, or products or services of our affiliated entities. When collecting information that could be used to contact you regarding our products and services, we give you the opportunity to opt out of receiving such communications. Additionally, each email communication we send you will include an unsubscribe option, allowing you to stop receiving that type of communication. If you choose to unsubscribe, we will remove you from the relevant list.

9. Retention

We will retain your Personal Information for the period necessary to fulfill the purposes described in this Data Management Statement, unless the law requires or permits a longer retention period.

10. Updates to this Management Statement

We may change this Data Management Statement occasionally and without prior notice. The legend "LAST UPDATED" at the top of this page indicates when it was last modified. Any changes will take effect when we post the revised Data Management Statement. Use of the Digital Offerings after these changes means you accept the revised Data Management Statement.

11. Contact

If you have any questions about this Data Management Statement, write to us at webelecmetal@elecmetal.cl