Privacy Policy

Summary

Michelin is committed to protecting your personal information and to taking a clear and transparent approach to the information we collect and how we will use it. This policy explains how we process the personal information that we collect, or that you provide to us, when you use our website or our digital services.

Please read the policy below carefully to understand our views and practices regarding your personal information and how we will process it.

Contents

1. Who we are and how to contact us
2. Our websites covered by this privacy policy
3. About our Data Protection Officer
4. Other policies and information we invite you to read
5. The information we may collect about you
6. Information about our marketing communications
7. The information we collect about you from other sources
8. Where we store your personal information
9. International transfers of personal data
10. Sharing your personal information
11. How long we keep your personal information
12. Your rights under data protection law
13. Your remedies if you are not satisfied
14. About data security
15. Changes to our privacy policy
16. Management of authorisations and credits for photos, videos and other content collected via Instagram/Facebook

1. Who we are and how to contact us

If you need to contact us, you have several options:

• send us an email at support_client_nazca@michelin.com
• send us a letter addressed to: Direction Commerciale France Bénélux, 23, place des Carmes, 63040 Clermont-Ferrand cedex 9, France

2. Our websites covered by this privacy policy

The information set out in this policy applies to the following websites: https://nazca.michelin.com/

3. About our Data Protection Officer

Although all Michelin employees are committed to protecting and respecting your privacy, we have a Data Protection Officer responsible for all matters relating to personal data at Michelin. You can contact the Data Protection Officer by sending an email using the contact details provided in the section “Who we are and how to contact us” or directly at privacy.fr@michelin.com.

4. Other policies and information we invite you to read

Additional privacy policies

This document is our main personal data policy regarding the use of the website and the digital services and products offered by Michelin. However, additional information may be included in personal data policies specific to certain digital products and services. Please consult those policies when you register for or subscribe to those products or services.

Our cookie policy

When you use our website or other digital products and services that we provide, information may be collected through cookies to distinguish you from other users of our website and other digital products and services. We have a separate cookie policy, which details our use of cookies and why we use them. We encourage you to consult our cookie policy here.

Linked platforms

Our website may, from time to time, contain links to and from the websites and digital platforms of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that they have their own privacy policies and that we cannot be held responsible for those policies. Please consult those policies before providing any personal information to those websites.

5. The information we may collect about you

This section sets out:

• how we collect your personal information;
• the categories of data we collect;
• how we intend to use the information we collect; and
• the legal basis on which we rely to process the information collected;
• the retention period for the information collected; and
• the specific types of data.

We may collect and retain the following information about you:

Voluntary information

When you provide us with information, for example the information detailed in the scenarios above, in some cases we will also ask you for additional information on a voluntary basis. This information will be presented as optional and used to help us better understand our customers and personalise our services.

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 users of our website who access a specific feature of our website. Aggregated Data is used solely for our own purposes.

Sensitive personal information

Although we do not request sensitive personal data, some sections of our websites allow you to submit additional information, for example when you submit a review. If you submit information in these free-text sections, please provide only information that you are comfortable sharing and always bear in mind that it may include sensitive information. If you submit comments or suggestions on our website, please remember that this information will be visible to other users of our website.

6. Information about our marketing communications

You will receive marketing communications or newsletters from us only if (i) you wish to receive them, (ii) you are already one of our customers, provided that the communication relates to similar services or products, or (iii) the communication is connected with your professional activity.

In this context, we use the information you provide to us, generally your name and email address.

In any event, you may unsubscribe or stop receiving any commercial prospecting from us at any time either:

• (i) by clicking on the unsubscribe link included at the bottom of each marketing communication we send you; or
• (ii) by contacting us by email or postal mail using one of the contact details set out in paragraph 1.

We may send you marketing communications until you decide to unsubscribe from receiving them. However, if we have not heard from you for a period of 3 years, or if we notice that you have not opened our emails, we will delete your contact details from our database. You may of course subscribe again at any time.

We may also use your Usage and Device Data to make online suggestions and recommendations to you about goods or services that may be of interest to you. This processing is based on our legitimate interest in developing our products and services.

7. The information we collect about you from other sources

• 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, technical subcontractors, payment services, analysts, search information providers or credit reference agencies, and may receive information about you from them. The legal basis for this processing is our legitimate interest in monitoring and improving our website, products and services.
• Information from our web server logs, for example information about your computer, such as your IP address, operating system or browser type (“Usage Data”). We use this information for system administration and to analyse how our websites and digital platforms are used. It also enables us to provide the best online infrastructure for your online activities. The legal basis for this processing is our legitimate interest in monitoring and improving our website, products and services.
• As mentioned above, we collect information using cookies or other similar technologies stored on your device about how you use our website and our digital products and services. Cookies contain information that is transferred to the hard drive of your computer or mobile phone/tablet. They allow us to improve our websites and provide you with a better and more personalised service. You can consult our cookie policy here. The legal basis for this processing is your consent or, where applicable, our legitimate interest in monitoring and improving our website, products and services.
• Our website may allow you to share your experience and communicate with us through third-party social networks such as Facebook and Twitter. We may collect this information on our social media pages, including likes, shares and tweets, as well as content from social media sites. We do not control the confidentiality of the information you provide on social networks, and the personal data policies of those social networks will apply when you use their services.

8. Where we store your personal information

All information you provide to us is stored on secure servers located in the EEA.

Although we are committed to protecting your personal information, the online transmission of information via the Internet is not completely secure. Together with our service providers, we will do our best to protect your personal information, but any information you provide is provided at your own risk.

9. International transfers of personal data

Michelin is an international group with databases in the various countries where it operates. Michelin may transfer your personal data within the group to one of its databases or to one of its external partners located in a country other than your own.

Because the level of data protection varies from country to country, we transfer your personal data to Michelin group companies or to third-party companies outside the European Union only where they provide the same level of protection for personal data as Michelin.

For transfers within the Michelin group, the company has adopted internal rules governing the transfer of personal data from the European Economic Area (EEA). You can find the details of these rules in the Michelin Binding Corporate Rules (BCR).

Transfers of data outside the group are governed either by our processor’s BCRs or by contracts containing the European Commission clauses, for providers established outside the EU, in order to ensure a level of protection similar to that of your country of origin.

10. Sharing your personal information

Your personal data will be disclosed only to persons who need to know that information in order to perform their duties.

We may share your personal data as follows:

Within the Michelin group

We may disclose your personal information to any member of our group, that is, our subsidiaries, our ultimate parent company and its subsidiaries, to the extent necessary to pursue the same purposes as the initial processing described in this policy. In particular, your contact details, such as your email address and interests, may be shared within the Michelin group in order to better understand you and send you marketing communications related to the newsletters to which you have subscribed.

With processors

Michelin may share your personal data with processors that the group may use to process your request or provide services. These processors are contractually required to ensure the confidentiality and security of the personal data received and to process your personal data only on our instructions.

With third parties

(i) For legal reasons

If we are required to disclose or share your personal information in order to comply with a legal obligation, or to enforce or apply our terms of use or any other agreement, or to protect the rights, property or safety of the Michelin group, its customers or others.

(ii) On the basis of your consent

Third parties may collect information about you on our website, products or services through cookies or similar technologies, for example to display personalised advertisements or carry out profiling. These cookies will be processed in accordance with our Cookie Policy.

11. How long we keep your personal information

By default, we will not keep your personal information for longer than is necessary for the purposes for which we collected it, including for the purpose of satisfying any legal, accounting or reporting requirement. For more specific information about how long your personal information is retained, please refer to paragraph 5 of this policy.

To determine the appropriate retention period for personal data, we take into account 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, whether we may achieve those purposes through other means, and applicable legal requirements.

The main retention periods that we apply to your personal data are as follows:

• for Marketing Data, three years from the later of the date of collection and the last contact from you regarding our newsletters and commercial communications;
• for Account Data, for as long as your account is active plus two years from your last activity on your account;
• one year for Usage Data.

In some circumstances, you may ask us to delete your data: please see your right to erasure below for more 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 that case, we may use this information indefinitely without further notice to you.

12. Your rights under data protection law

Data protection law gives you certain rights in relation to the processing of your information. These rights are as follows:

• The right to be informed
• The right to access your information
• The right to correct your information
• The right to delete your information
• The right to restrict processing
• The right to data portability
• The right to object to processing
• The right to define what happens to your data after your death

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 included all the necessary information in this privacy policy.

The right to access your information

You have the right to access the personal information about you that we hold. We can confirm whether or not your information is being processed and give you access to your personal information.

The right to correct your information

If your personal information is inaccurate or incomplete, you are entitled to have it corrected and updated. If we have disclosed your information to third parties, where possible, we will inform them of any updates you provide to us. You can update the personal information about you that we hold by contacting us using the contact methods set out 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 we have no reason to continue processing it. The circumstances in which you may exercise the right to be forgotten include situations where the information is no longer necessary for the purpose for which it was originally collected or processed, and situations where you have withdrawn your consent to the processing.

In certain limited circumstances, the right to be forgotten does not apply. If you would like to know more, please ask us.

The right to restrict processing

You have the right to “block” or prevent the processing of your personal information. If you ask us to block your personal information, we will stop processing it.

The right to data portability

If you wish to move or transfer your personal information to another 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 to processing

You have the right to ask us not to process your personal information for marketing purposes or, where applicable, not to share your data with other Michelin Group companies. 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. You may exercise your right to prevent this type of processing by ticking certain boxes on the forms we use to collect your information. You may also exercise this right at any time by contacting us at support_client_nazca@michelin.com.

The right to define what happens to your data after your death

You also have the right to tell us what you would like us to do with your data after your death. We will record your instructions and, if we become aware that such an event has occurred, comply with them.

You can find further information about your data protection rights from the French Data Protection Authority, the Commission Nationale de l’Informatique et des Libertés, at http://www.cnil.fr, or from your local supervisory authority.

13. Your remedies if you are not satisfied

We are committed to protecting and respecting your privacy. However, if you are not satisfied with how we collect or process your information, or if you simply wish to obtain further information about your rights, you may contact us using the following methods:

• You may send us a letter addressed to the Data Protection Officer: Direction Commerciale France Bénélux, 23, place des Carmes, 63040 Clermont-Ferrand cedex 9, France
• You may also contact us by email at support_client_nazca@michelin.com using the subject “Deletion of personal data”.

We will endeavour to resolve with you any issue you may encounter and to answer all your questions as soon as possible.

You may also lodge a complaint with the CNIL (more information here) or with your local supervisory authority.

14. About data security

Michelin has implemented measures to protect the confidentiality, security and integrity of your personal data. Access to personal data is restricted to employees and service providers who need to know this information and who have been trained to comply with confidentiality rules.

On Michelin’s commercial websites, banking information will be collected in order to provide efficient, lawful and secure payment processes. These measures may include SSL encryption, the purpose of which is to make data unreadable by third parties, during the collection or transfer of confidential data. The information mentioned above will be used only for online payment and will not be retained.

Michelin undertakes to ensure that your personal data is not altered or damaged and that unauthorised third parties do not have access to it.

15. Changes to our privacy policy

We may make changes to our policy from time to time. Any future changes to this policy will be published on this page. If you have an online account with us, we may notify you of any change by email or through your account the next time you log in.

16. Management of authorisations and credits for photos, videos and other content collected via Instagram/Facebook

Manufacture Française des Pneumatiques Michelin (“Michelin”), as data controller, implements personal data processing for the purpose of managing authorisations and credits for photos, videos and other content collected via Instagram/Facebook or via the photo/video upload tool provided by Pixlee Inc. (the “Content”).

The legal basis for this processing is your acceptance of the Terms of Use (the “Terms”).

Personal data is retained for as long as Michelin retains these photos/videos. If you would like Michelin to stop publishing your Content, we will stop publishing the Content and archive your personal data and the Content for a period of 3 years for evidentiary purposes.

These data are reserved for use by Michelin and its employees, as described in the Terms, and/or by any Pixlee employee, as Michelin’s service provider. Pixlee, as a service provider acting on behalf of Michelin, may store these data on Michelin’s behalf.

Pixlee is located in the United States. To provide adequate safeguards for the protection of users’ personal data, a cross-border data transfer agreement containing the European Commission’s standard contractual clauses has been signed between Michelin and Pixlee.

In accordance with the General Data Protection Regulation, known as the “GDPR”, you have the right to access, rectify, object to and delete your data, as well as the right to define instructions regarding what should happen to your data after your death. You can exercise these rights by sending an email to: support_client_nazca@michelin.com.

If you are not satisfied with how we process your personal data, you may lodge a complaint with the CNIL (cnil.fr).

(August 2024 version)