PRIVACY POLICY
Abstract
Michelin is committed to protecting your personal information and being clear and transparent about what information we collect and how we will use it. This policy explains how any personal information we collect when you use our website or digital services, or that you provide to us, will be processed by us.
Please read the following policy carefully to understand our views and practices regarding your personal information and how we will treat it.
1. Who we are and how we can be contacted?
Our full company name is Manufacture Française des Pneumatiques Michelin (“Michelin”) and when you use our website and our services directly, we act as a Data Controller.
If you need to contact us by e-mail : Operations-QS@michelin.com
2. About our Privacy Department
Everyone at Michelin is committed to protecting and respecting your privacy and we have a data protection Privacy Department who deals with all aspect of personal data at Michelin. You can contact them sending by email to privacy.fr@michelin.com .
3. Information we may collect from you
This section sets out:
• how we collect your personal information;
• the categories of data that we collect;
• a description of how we plan to use the information we collect;
• the legal basis that we will rely on to process information collected;
• how long we will hold the information collected; and
• specific types of data
We may collect and hold the following information about you:
Data collected | Purpose/Activity | Type of Data | Lawful basis for processing | Retention period |
To enable you to participate in this event ("Registration data") | Management of registrations for participation in the event | This information may include your Last Name, First Name, E-mail | Your consent that you show by participating in this event | We keep the information 1 year after the end of the event |
Information you provide us when you communicate with us, e.g. by email or contact us form via our websites or through the live chat function on our website (“Communication Data”) | This information is used to enable us to respond to or following up on your comments, queries or questions | Information may include your full name, your email address and other personal data you provide us to enable us to deal with your communication. | We will use our legitimate interests in the assisting you and answering your communications as the legal basis for processing Communication Data. | We will hold on to Communication Data for as long as it is necessary to enable us to deal with the matter relating to that communication. Once your matter has been dealt with, we will delete Communication Data within 6 months. |
Voluntary Information
When you provide us information (for example, the information set out in the scenarios above), in some cases we may ask you for additional, voluntary information. This information will be identified as optional and is used to help us better understand our customers and tailor our services to them.
Statistical Information
We also collect and use aggregated data such as statistical or demographic data (“Aggregated Data”). Aggregated Data may be derived from your personal information but does not reveal your identity in any way. For example, we may aggregate your Usage and Device Data to calculate the percentage of our website users accessing a specific feature of our website. Aggregated Data is used for our own business purposes only.
4. Information we collect about you from other places
To enable us to provide you with our services, we may receive personal information about you from other sources, including:
• We may receive information about you if you use any of the other websites we operate or the other products and/or services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment services, analytics providers, search information providers and credit reference agencies) and may receive information about you from them. The legal basis for his processing is our legitimate interests, namely monitoring and improving our website, products and services.
• Information from our web servers’ logs, for example information about your computer, such as your IP address, operating system and browser type. We may also collect information on the searches you carry out on our website and your interaction with communications we send you, for example, when you open email communications. (“Usage and Device Data”). This information is used by us for system administration and to analyse how people are using our websites and digital platforms. It also helps us to provide the best online infrastructure for your online activities. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website, products and services.
5. Where we store your personal information
All information you provide to us is stored on secure servers within EEA.
While we are committed to keeping your personal information secure, the transmission of information online via the internet is not completely secure. We, together with our service providers will do our best to protect your personal information but information provided is at your sole risk.
6. Sharing your personal information
We only share your personal data with people who have a need to know such information to perform their responsibilities. We may share your personal information with the following:
• Within the Michelin Group - we may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries to the extent necessary for the same purposes of the initial processing set out in this policy.
• Service Providers - Michelin may share your personal information with selected service providers that Michelin may use to process your request or provide its services to you. These service providers act as data processors on our behalf and provide IT and system administration services, such as hosting and email services and managing the ratings and reviews. These service providers are legally obligated to keep the personal information they may have received confidential and secure and to use your personal information the basis of our instructions only.
• Third parties for legal reasons - If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of the Michelin Group, our customers, or others. In this context, we may disclose your personal information to our professional advisors who are under a duty of confidentiality.
7. International Transfers of Personal Data
Michelin is an international group with databases in the various countries in which it operates. Michelin may transfer your personal data within the group to one of its databases or to its external partners located outside of your home country.
As levels of data protection vary worldwide, we do not transmit your personal data to Michelin group companies or to third-party companies outside of the European Union unless these companies offer the same or similar level of personal data protection as Michelin.
For transfers within Michelin, the company has adopted internal rules governing the transfer of personal data from the European Union or European Economic Area.
Transfers of data outside the group are governed either by the BCR of the subcontractor or by contracts containing the clauses of the European Commission for suppliers established outside the EU to guarantee a similar level of protection as that of your home country.
8. How long will personal information be kept by us?
As a rule, we will not hold your personal information for any purpose or purposes for longer than is necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. For more specific retention periods, please see section 3 above.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see your right to be deleted below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your rights under data protection legislation
Data protection legislation provides you with certain rights when it comes to the processing of your information. These are the right to:
The right to be informed
You have the right to be informed about how we collect and process your personal information, including who we are, how we use your personal information and your rights in relation to your personal information. We have gathered all the information you need in this privacy notice.
The right of access your information
You have the right to access the personal information we have on you. We can confirm whether or not your information is being processed and provide you with access to your personal information.
The right to correct your information
If your personal information is inaccurate or incomplete, you are entitled to have that information corrected and updated. If we have disclosed your information to any third parties, where possible, we will inform them of any updates you provide to us. You can update the personal information we hold about you by contacting us using any of the contact methods details in this Privacy Policy.
The right to delete your information
You have the right to request the deletion or removal of your personal information where there is no reason for us to continue to process it. The circumstances in which you can request the right to be forgotten includes, where the information is no longer necessary in relation to the purpose for which it was originally collected or processed and where you have withdrawn your consent to processing.
There are some limited circumstance where the right to be forgotten does not apply – if you want to know, just ask.
The right to restrict processing
You also have the right to ‘block’ or suppress the processing of your personal information. If you request us to suppress your personal information, we will stop any further processing of it.
The right to transfer information
If you want to move or transfer your personal information to a different service provider or copy your information for your own purposes, you have the right to have your information transferred to another person.
The right to object
You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes.
The right to define the outcome of your personal information after your death
You have the right to give us instructions on what we wish that we do with your personal information after your death. We will register it and if we heard that such event occurred, we will comply with your instructions.
For further information on your rights
You can find further information on your data protection rights from the CNIL or with your local supervisory authority.
10. What can you do if you’re not happy?
We are committed to protecting and respecting your privacy. However, if you’re not happy with how we collect or process your information or just want some further information on your rights, you can contact us by email to: Operations-QS@michelin.com .
We will work with you to resolve any issues you may have and aim to answer any question raised by you as soon as possible.
You can also make a complaint to the CNIL, further information can be found at cnil.fr.
11. About Data Security
Michelin has implemented measures to protect the privacy, security and integrity of your personal data. Access to personal data is restricted to those employees and service providers who need to know this information and who have been trained to comply with rules on confidentiality.
On Michelin's commercial sites, banking information will be collected for the purposes of effective, legal secure payment processes. These measures may consist of SSL encryption (intended to make the data unreadable to others) during the collection or transfer of confidential data. Said information will be used only for purposes of online payment and will not be retained.
Michelin ensures that your personal data are not altered, damaged or accessed by unauthorised third parties.
12. Changes to our Privacy Policy
We may change our policy from time to time. Any changes we make to this policy in the future will be posted on this page. If you have an online account with us, we may notify you of any changes by email or through your account the next time you log on.
Date: 2023, September