This Privacy Policy describes how any branch, affiliated company, or other entity directly or
indirectly controlled by Xuzhou Construction Machinery Group Co., Ltd. (hereinafter referred to as "XCMG" or
"we") collects, stores, uses, and transfers personal information. We understand the importance of privacy to
our customers and related individuals (collectively referred to as "you") and are committed to protecting the
security and reliability of your information.
Scope of Application
This Privacy Policy applies to Xuzhou Construction Machinery Group Co., Ltd.
and its affiliated companies in China, including any branches, affiliated companies, or other entities
directly or indirectly controlled by Xuzhou Construction Machinery Group Co., Ltd. (collectively referred to
as "XCMG").
This Privacy Policy applies only when XCMG collects or processes personal information for its own
purposes (when XCMG either alone or jointly with other entities acts as a controller, determining the purposes
and means of processing any personal information). It does not apply when XCMG collects or processes personal
information on behalf of other companies (such as XCMG’s dealers, suppliers, or customers).
The applicable XCMG entity acting as the "controller" of your data refers to the entity with which you
have a relationship—for example:
- As a customer (e.g., the XCMG mentioned in your purchase order or
other agreements with XCMG), - As an employee (e.g., the XCMG you are seeking or have established an
employment relationship with), - As a supplier (e.g., the XCMG you are seeking or have established a supplier
relationship with). We encourage you to review this Privacy Policy regularly to stay informed of any updates.
For convenience, this Privacy Policy is structured into sections based on the categories of data subjects
listed below. Please note that in some cases, you may not fit neatly into a single category (e.g., multiple
categories may apply, or you may not be an XCMG customer, but the "Customer" section may still be the most
relevant). Please review all sections that apply to your relationship with XCMG. This Privacy Policy covers
the personal information of the following individuals:
"XCMG job applicants or employees (referring to staff, personnel, workers), or other individuals
currently or formerly employed by XCMG, including temporary workers (collectively referred to as 'Employees');
individuals related to XCMG’s customers, including dealers, dealers’ customers, distributors, distributors’
customers, direct sales customers, sales representatives, and other resellers (collectively referred to as
'Customers'); and individuals related to XCMG’s suppliers, such as suppliers’ employees (temporary workers,
staff, personnel, contractors, etc.) (collectively referred to as 'Suppliers').
In this Privacy Policy, the term 'processing' refers to any activity performed on personal information,
including collection, storage, modification, transfer, or use of the information. Additionally, this Privacy
Policy does not apply to other information (non-personal information) that XCMG may collect or process. For
more details about other information XCMG may collect or otherwise process, please refer to XCMG’s Data
Management Statement.
In addition to this Privacy Policy, certain other XCMG systems, applications, and processes may include
their own privacy notices, which provide further details on what specific personal information is collected
and how it is stored, used, and transferred.
Some countries or regions may prohibit or restrict the collection, use, or sharing of certain categories
of personal information; therefore, this Privacy Policy describing our practices may be limited by such laws
and/or further clarified in any country-specific appendices attached to and applicable to you under this
Privacy Policy. In the event of any conflict with this Privacy Policy, such appendices shall prevail."
Personal Information
In this Privacy Policy, Personal Information refers to any information relating
to an identified or identifiable individual. In other words, it includes any information that may be
associated with you. Certain countries or regions may prohibit or restrict the collection of specific
categories of personal information. In compliance with local laws and any appendices to this document, we may
collect, use, transmit to data recipients, and entrust them with processing the following information about
you and the equipment you purchase:
Your basic information, including name, personal ID number/unified social credit code,
address, contact details, and equipment identification number;
Your internal credit investigation data and rating information, which refers to the internal
credit assessment and rating information that you authorize us to access when purchasing construction
machinery products or using related services;
Your transaction and service information, including your historical purchase records (such as
purchase date, equipment model, product group, and serial number), product failure and maintenance records,
satisfaction ratings, feedback comments, and equipment repayment data;
Equipment data: When you use construction machinery purchased from XCMG, we may collect, use,
transmit to data recipients, and entrust them with processing equipment data. This includes data generated,
collected, or stored by your equipment or related hardware/devices, such as geographical location,
manufacturing date, operational/downtime records, fuel consumption, and component replacements.
If you are a sole proprietor or individual business owner, information related to your company or
yourself may be considered personal information, including the basic details mentioned above (e.g., name,
personal ID number, address, contact information), your internal credit investigation data and rating
information, as well as your transaction and service records (e.g., purchase history records, equipment
repayment data).
Collection and Use of Information
We may collect your information through the following channels:
Directly through you– When you interact with us, including but not limited to inquiring about
products or services, purchasing equipment or products, or using our services, we may collect your
information directly based on the details you provide and records from service interactions.
XCMG official website – When you register an account, log in, or access relevant websites or
cloud services on our official website, we may collect your information based on the details you provide or
through tools such as cookies.
When you use the E-Route App, you log in with an account that has been pre-registered and assigned through XCMG's administrative backend. Accounts can be created in two ways:
Directly by XCMG's system administrators for customers who have established a business relationship with XCMG;
By authorized XCMG dealers or agents, who have the permission to register accounts for their own customers through the backend system.
The App does not offer public self-registration. Instead, account credentials (username and password) are issued to you via offline business procedures, including but not limited to contract signing, equipment procurement, and service activation. After logging in, the App will collect and present your equipment data and service information, as well as other related information, in accordance with this Privacy Policy.
Your equipment– When you use construction machinery purchased from XCMG, if permitted by the
device settings, we may also collect your information through the corresponding equipment.
We will collect, use, transmit to data recipients, and entrust them with processing your relevant
information for the following purposes:
Data aggregation and analysis – We may consolidate the information you provide or generate
when purchasing different construction machinery products, entrust data recipients to perform data analysis,
and produce corresponding analytical reports.
Personalized products and services – We may use the generated analytical reports to offer you
tailored products and services, including but not limited to recommending construction machinery products
and service information that match your needs, providing customized support, and meeting your unique
requirements.
We commit to transmitting and entrusting data recipients with processing "customer
information related to this policy" only when necessary for the operation of the E-Route.
Information Protection and Retention Period
XCMG employs reasonable measures, including IT security and physical safeguards, to protect personal
information. These measures are appropriate for the risks associated with processing personal information and
its sensitivity, while complying with applicable local laws. XCMG requires all personnel using its systems to
adhere to relevant security policies concerning personal information.
XCMG retains personal information for as long as necessary to fulfill the purposes outlined above and
meet legal requirements, including record-keeping obligations. The retention of your personal information is
always subject to local laws and may extend beyond the duration of your relationship with XCMG.
In accordance with local laws and the procedures established by relevant XCMG systems or processes,
personal information will be securely destroyed when it is no longer needed or, in any case, once the legal
authorization for retention has expired.
Transfer or Sharing of Personal Information During Data Usage
As E-Route operates globally, we may need to transfer your personal information to different
countries/regions for business purposes. The E-Route may transfer personal information to jurisdictions that
may not legally mandate the same level of protection for personal information. This Privacy Policy applies to
all E-Route operations and data processing activities. XCMG has entered into data transfer agreements with
its global affiliates to safeguard personal information.
XCMG will only share personal information with others in a manner consistent with this Privacy Policy,
for the purposes stated above, when required by law, or with your consent. Transfers to third parties are
typically made to data processors for purposes aligned with this Privacy Policy. Additionally, XCMG may
transfer personal information to third-party data controllers as required by law, with your consent, or upon
approval by relevant authorities. In certain countries/regions, the transfer of specific categories of data or
to certain third parties may require your explicit consent. In all cases, such transfers are subject to local
laws and any appendices to this document.
When XCMG shares personal information with third parties processing data on its behalf (e.g.,
contractors, consultants), it will take reasonable measures to require such recipients to protect the
information in accordance with applicable laws. Examples of third parties with whom we may share information
for these purposes include:
- Suppliers, service providers, and business partners supporting our
operations, such as those providing technical infrastructure services;
- Law enforcement or other
government agencies;
- Subsidiaries, affiliates, and other entities controlled by XCMG;
-
Third-party service providers processing personal information on behalf of XCMG;
- Potential or actual
purchasers in the event of a business divestiture (or consideration thereof);
- (Employees only) Vendors
providing medical or financial planning services.
Your Rights
E-Route takes steps to maintain the accuracy and integrity of personal information.
You may request and obtain reasonable access to the personal information you provided to E-Route and, where
necessary, correct it. The E-Route enables you to access your personal information and exercise other rights
you may have under applicable local laws.
Unless prohibited by local law or in cases where legal restrictions apply, your right to access personal
information may be limited. Examples of such limitations include:
- The request involves legal advice or
litigation;
- Legal privilege could be claimed over the subject matter;
- The personal information
includes third-party data whose disclosure would affect their privacy without consent;
- The request is
insufficiently specific or has already been addressed.
E-Route will consider local laws when reviewing requests to access or modify personal information it
holds.
- Customers: Contact the XCMG representative to whom you provided your personal information to learn how
to access it.
- Employees: Reach out to your local, regional, or corporate HR representative for access
procedures. Upon request, and after verifying your identity and meeting any local legal requirements, you may
access, copy, amend, delete, or challenge the relevant personal information in E-Route systems.
-
Suppliers: Contact the individual in your organization responsible for managing the XCMG Group relationship,
maintaining network security credentials, and/or accessing supplier data management applications for
"self-service" access.
Changes
We reserve the right to modify this Privacy Policy as needed. If changes are made, we will
notify affected individuals and indicate the date and/or effective date of such revisions at the top of this
Privacy Policy. In certain cases, particularly for material changes, we may also notify you via email or other
communication channels, informing you of the changes and any options or actions you may take before the
changes take effect. Depending on the nature of the changes and applicable local laws, your continued
engagement with XCMG will constitute acceptance of the updated terms.
Contact Us
If you have any questions or suggestions regarding this policy or your personal
information while using the E-Route, please contact us at xgssglobal@xcmg.com. You may be required to
provide proof of identity, valid contact details, and a written request with supporting documentation. We will
process your request after verifying your identity. We will review the matter promptly and respond within
fifteen 15workings days after verifying your user identity.