Privacy notices for product and service improvement as well as for improvement of business and sales processes.

Daimler Truck processes the following categories of data ("vehicle data") for the purpose of product and quality improvement, product development and improvement of sales and business processes:

• Diagnostic data: Technical data to determine the condition of the vehicle (for example maintenance data, status monitoring, wear-and-tear data, consumption figures, mileages, load spectra, information from or about control units, as well as data regarding current defects as well as the defect log). This vehicle data covers the entire vehicle, including trailers and semitrailers.
• Data from driving assistance systems (e.g. system states/behaviour, (de)activations, user interactions, warnings, interventions)
• Vehicle identification number ("VIN"), control unit identification numbers and, if applicable, Identification numbers of the trailer and/or semi-trailer
• Geopositioning data and speed
• Times of data collection, also in so-called Time series (=several consecutive times recorded at regular intervals)

Vehicle data is transmitted directly from the vehicle to Daimler Truck via a wireless network connection. Depending on the use case, these data is collected as follows:

• Event-based (for example if the sensors and test routines in the vehicle that monitor the vehicle systems detect a deviation from control system functions),
• Periodically (for example by recorded ambient conditions, depending on mileage or at certain time intervals, e.g. once a week),
• In detail using groupage orders that the vehicle receives.

Depending on the application, vehicle data can be supplemented with data on vehicle equipment, information on repairs carried out, information from business or sales processes, information from service contracts and information from other internal processes (e.g. production or logistics).

Insofar as it is not necessary for the use case or for merging certain information, the vehicle data transmitted from the vehicle is separated from the VIN or other identifiers and processed in pseudonymised or anonymised form.

When using pseudonymised data, Daimler Truck can distinguish between individual vehicles. However, Daimler Truck is not in a position to directly identify individual vehicle users on the basis of this data. When using anonymised data, processing takes place without assignment to individual vehicles, customers or vehicle users.

The vast majority of the vehicle data processed by Daimler Truck are technical operating data of the vehicle, which, even with reference to the VIN or other identifiers, do not allow any direct conclusions to be drawn about the driving behaviour or operation of an individual vehicle user.

The remaining vehicle data collected by Daimler Truck may also be related to the behaviour of the vehicle user.

In principle, neither the identification of individual vehicle users nor the creation of individual driver profiles is the aim of processing and is not required for these.

Daimler Truck also uses self-learning algorithms for product and quality improvement, product development as well as to improve internal sales and business processes. In order to develop self-learning algorithms, it is necessary to collect and subsequently analyse large amounts of data from a large number of vehicles with the aim of gaining structures, patterns, models, predictions and/or other insights about vehicles.

Daimler Truck uses existing self-learning algorithms to determine the behaviour of, for example, to better understand vehicles, vehicle parts or individual components and then, for example, to derive conclusions that can be used for product and quality improvement as well as product development (e.g. predictive maintenance management, battery service life).

Vehicle data is processed in connection with product and quality improvement, product development and improvement of sales and business processes, in particular for the following purposes:

Improvement and development of vehicle components and systems:

• Analysis of vehicles, systems and components in series production to identify any quality problems that may exist and their causes, and to initiate the necessary measures to eliminate faults and improve quality.
• Further development or optimization of vehicles, systems and components, e.g. by compiling usage statistics (e.g. start-stop function) and test cases (e.g. service life tests of vehicle components)
• New development of vehicles, systems and components (e.g. development of alternative drives)

Improvement and development of digital services (for example Mercedes‑Benz Uptime Service:

• Quality analysis as well as further development or optimization of existing rules to increase the effectiveness of warnings, information and recommendations, early fault detection and preventive maintenance/repair as well as fault and problem analysis.

Business and sales management:

• Evaluation of key performance indicators (e.g. mileage, wear data) to optimize sales potential and to derive measures in the customer & sales process to improve customer satisfaction

Daimler Truck processes the above-mentioned vehicle data to the extent required for the safeguarding of its legitimate interests and insofar as the interests or fundamental rights and freedoms of the data subject which require protection of personal data do not override these interests (Art. 6 (1) S. (1) (f) GDPR. The processing on the basis of a legitimate interest described herein takes place in connection with product and quality improvement, product development as well as sales and business management.

For the data processing described above, Daimler Truck uses the services of contractors, e.g. IT service providers and research institutes. These can also be Daimler Truck Group companies. This data is passed on to these contractors. This ensures that the contractors are subject to the same contractual obligations with regard to confidentiality, data protection and data security.

Daimler Truck regularly discloses the personal data transferred as part of the processes described above only to a limited number of individuals with specific roles, to whom personal data is only accessible to the extent necessary for the performance of their respective duties. This applies not only to employees of Daimler Truck, but also to contractors, service providers for IT, Group companies, insofar as this should be necessary for the performance of the relevant tasks.

In individual cases, personal data may also be transferred to law enforcement agencies, government authorities or regulatory authorities if so required by law.

Personal data is generally not processed outside the EU/EEA. In exceptional cases, service providers who operate our systems for us, potentially in non-European countries, may be able to access the aforementioned data in the event of system maintenance. Our service providers do not actively process this data, but for organizational reasons, the possibility of access cannot be ruled out. We currently use a service provider in India for the operation of the systems used for the aforementioned purposes. If personal data is transmitted outside the EEA, the EU Commission "standard contractual clauses", which can be accessed at https://ec.europa.eu/info/law/law-topic/data, shall generally apply.

The vehicle data processed for product and quality improvement , product development and improvement of sales and business processes will be stored for as long as necessary to carry out the product and quality improvement , product development and improvement of sales and business processes and then anonymized or deleted.

You have extensive rights with regard to the processing of your personal data. It is particularly important for us to familiarize you with these rights:

• Right to information: You have the right to access personal data stored by us, particularly to determine for what purpose the data is processed and how long the data is stored (Art. 15 GDPR).
• Right to correction of inaccurate data: You have a right to demand from us the immediate rectification of your personal data, should it be inaccurate (Art. 16 GDPR).
• Right to erasure: You have the right to demand that we erase the personal data relating to you. You can demand the deletion of your personal data if we, for instance, no longer need the personal data for the purposes for which it was collected or otherwise processed, if we unlawfully process the data, or if you have rightfully objected to the use of your data, or there is a legal obligation to delete it (Art. 17 GDPR).
• Right to restriction of processing: You have the right to demand restricted processing of your data. This right exists in particular for the duration of the check, if you have disputed the correctness of the data concerning you, as well as in the case that you wish restricted processing with an existing right of erasure rather than the erasure. Furthermore, there will be a restriction of processing in the case that the data is no longer needed for our purposes, but you still need the data in order to assert, exercise or defend legal rights, as well as if the successful assertion of an objection is disputed between you and us (Art. 18 GDPR).
• Right to data portability: You have the right to receive personal data about you that you have provided to us in a structured, standard, machine-readable format (Art. 20 GDPR) if it has not been deleted yet.

To exercise these rights, the data subject may send an e-mail to dataprivacy@daimlertruck.com.

For reasons relating to your particular situation, you have the right to file an objection at any time to the processing of personal data pertaining to you that is collected under Art. 6 1 sentence 1 f) GDPR. We will no longer process your personal data unless we can prove compulsory, legitimate reasons for processing that outweigh your interests, rights and freedoms, or if the processing is required to assert, exercise or defend against legal claims. To exercise your right to object, please e-mail us at dataprivacy@daimlertruck.com.

If you feel that we are violating the GDPR by processing personal data about you, you have the right to lodge a complaint with a supervisory authority, e.g. a data protection agency responsible for your place of residence, workplace or location where the alleged data protection violation occurred.