Summary
Please read the following policy carefully to understand our views and practices regarding the personal information of legal representatives, employees or end users of our professional customers (including but not limited to dealers, fleets, fleet managers, transportation companies) and how we will treat it as part of the products or services we provide.
Michelin acts as data controller for the personal data of its professional customers, that are collected or processed by Michelin for its own purposes, regardless of the needs of its customers and for which it alone determines the means of processing, outside the contractual documentation agreed with the customer.
Michelin can, as a supplier of products and services, act as a controller for the management of its commercial activity (including but not limited to contract management, management of loyalty programs, conducting satisfaction surveys, customer studies, claims management, management of the improvement of its products and services, development of new products and services, predictive analytics).
When a professional customer concludes a contract with Michelin, Michelin acts as a processor for all personal data that is communicated to it or that is collected or generated by Michelin to provide the services to the concerned customer, according to its instructions and for the satisfaction of its own needs. Each Michelin customer defines the purpose of the processing that it implements as part of the service it subscribes. The processing of personal data is described in the contractual documentation agreed between the customer and Michelin.
If you need to contact us as data controller or data processor you can send us an e-mail addressed to sescn.tech@michelin.com.
While everyone at Michelin is committed to protecting and respecting your privacy, we have a Data Privacy organization who deals with all aspects of personal data at Michelin. You can contact this team by sending an email to privacy.fr@michelin.com
This section sets out how, when we are (i) on the one hand, data controller:
· how we collect your personal data,
· the categories of personal data that we collect,
· a description of how we plan to use the data we collect,
· the legal basis that we will rely on to process data collected,
· how long we will hold the data collected, and
· specific types of data,
as well as (ii), on the other hand, the way we use data when we act as data processor.
i. Personal data processed by Michelin as data controller
|
Collected data |
Purposes |
Type of data |
Legal basis of the processing |
Retention period |
|
Customer data as part of the commercial activities of Michelin |
Customer / prospect relationship management |
Identification data: name, surname, professional contact details |
The conclusion of a contract with Michelin for the supply of the requested products or services and the legitimate interest of the data controller for the prospects. |
The retention period depends on the nature of data according to the legal retention obligations that can last up to the time when the account is completely deleted and until the end of applicable limitation periods if required.
|
|
Information you provide to us when you complete a survey or respond to a questionnaire or submit a review or feedback (“Review Data”). |
To collect information about a specific matter, for example, our services to you or reviews of our products/services. In many cases surveys, and questionnaires are anonymous, and we only collect personal information for statistical data. If this is not the case, we will let you know at the time of collecting the information. |
Information may include your full name, your email address and other personal data requested. |
As the legal basis for processing Review Data, we will use our legitimate interests in the monitoring and improvement of our products and services to our customers and users. |
3 years after sending replies or any duration mentioned where the data is collected. |
|
Information we use to send you one of our newsletters or marketing communications |
Commercial communications management, performing audience analysis and statistics. Keeping an up-to-date list of opposition if you asked not to be contacted. |
Name and e-mail address |
Performing audience analysis and statistics. Keeping an up-to-date list of opposition if you asked not to be contacted. |
Your information will be kept for 3 years after the last contact. |
|
Information related to the services provided |
Improvement of our products and services |
Usage data of our services such as alerting data, reportings, |
The legal basis is our legitimate interest as a data controller to improve our products and services and develop new services. |
The data is aggregated and therefore anonymized. |
|
Information related to your Michelin user account only (“Account Data”). |
Account Data will be processed for the purpose of operating our websites, providing digital services you sign up for, communicating with you about those digital products and services and maintaining back-ups of our services. |
Account Data will include your full name, email address. We may also ask you to set a password so you can securely log on to your account. |
The performance of the agreement between you and us for the provision of the digital product and services is the legal basis for processing Account Data. |
We will retain Account Data for as long as you have an account with us. If you do not access your account for 24 months, we will delete your account data so that we do not keep information for longer than is necessary. You can of course, create a new account if you like. |
ii. Personal data processed by Michelin as data processor
|
Data collected or processed |
Type of data |
Retention period |
|
Data necessary for the services provided such as the inspection (collect semi-manual and automatic) |
Identification and professional contact details |
Retention period necessary to provide the services or longer if required and specified in the contractual documentation agreed between the customer and Michelin |
|
Access by customers for their own needs to the portals and applications made available by Michelin and corresponding use |
Identification and professional contact details |
Retention period necessary to provide the services or longer if required and specified in the contractual documentation agreed between the customer and Michelin |
|
Hosting data and related services |
Identification and professional contact details, stored data |
Retention period necessary to provide the services or longer if required and specified in the contractual documentation agreed between the customer and Michelin |
|
Service Request management |
Identification and Professional contact details |
Retention period necessary to provide the services or longer if required and specified in the contractual documentation agreed between the customer and Michelin |
|
Commercial exploitation of vehicle data as part of vehicle value-added services |
Technical data of the vehicle, asset management |
Retention period necessary to provide the services or longer if required and specified in the contractual documentation agreed between the customer and Michelin |
Voluntary Information
When you provide us information (for example, the information set out in the scenario 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.
Aggregated Data
The aggregated usage data of the vehicle and of the services (i.e. without any link with an identified or identifiable natural person) may be used by Michelin without restriction.
You will receive marketing communications or newsletters from us only (i) if you are one of our customers, provided that this communication will concern similar products or services or if (ii) this communication is linked to your business activity.
In this context, we will use the information you provide us, usually just your name and email address.
In any case, you can unsubscribe or make stop direct marketing from us at any time either:
(i) by clicking on the unsubscribe option at the bottom of each marketing communication we send to you; or
(ii) by contacting us by email or letter using any of the contact details set out in this notice.
We will generally send you marketing communications until you choose to unsubscribe from receiving them. However, if we have not heard from you for a while or notice that you have not opened our emails in a period of 3 years, we will remove your details from our database. There’s nothing stopping you for subscribing again at any time.
All information you provide to us is usually stored on secure servers. Otherwise, the location of the accommodation of your data will be specified in the contractual documentation agreed between the customer and Michelin.
As data controller or data processor, we may share your personal data with other Michelin entities or with selected service providers/suppliers established in the European Union or outside the European Union. For more information, refer to the contractual documentation approved with the customer which lists the subcontractors/processors used by Michelin.
We require all third parties to respect the security of our customers' personal data in accordance with our standards and to treat them in accordance with applicable data protection laws. We do not allow our external suppliers to use the personal data of our customers for their own purposes. We only allow them to be processed for the purposes specified and in accordance with our instructions and under the conditions defined in our agreements.
All Michelin entities when they are responsible for processing are bound by Binding Corporate Rules (BCR) relating to the transfer of personal data outside the EU. When we transfer personal data to an external supplier / service provider established outside the EU in a country that does not offer an adequate level of protection, we sign with these suppliers / service providers the European Commission Standard Clauses that confer on the customer's personal data the same protection as in the EU. We may also transmit them to third parties if we are obliged to disclose them in order to comply with a legal obligation, or to enforce or apply our terms of use or any other contract; or to protect our rights, property or the safety of Michelin Group, its customers or others. In this context and to the extent that it is necessary, we may transmit your personal information to any external consultant who is bound by an obligation of confidentiality.
As a rule, when we are data controller, we will not keep your personal data for any longer that it is necessary for the purpose under which the personal data is processed, whatever the purpose, including for the purpose of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period of personal data, we take into account the quantity, nature and level of sensitivity of personal data, the potential risk represented by unauthorized use or disclosure of your personal data, the reasons why we are processing your personal data, our potential ability to pursue these purposes by other means and the legal requirements in force.
In certain circumstances, you may ask us to delete your data: see your right to deletion below for more information.
We may anonymize your personal data (so that they can no longer be associated with you) for reasons of research, statistics, improvement of our products and services, and development of new products, services or offers. In this case, we may use this information indefinitely and for any other purpose, without informing you.
When Michelin acts as a processor, the retention period of the data is related to the duration of supply of the services and it is the responsibility of the customer, responsible for processing (data controller) to determine it. To find out more refer to the contractual documentation agreed with the concerned customer which also defines the retention period agreed with the customer as part of the service provided.
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
· 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 transfer information
· The right to object to processing
· If you wish to exercise your rights regarding your personal data that Michelin treats as a data controller, you can contact us using the online contact form. You can also fill out and print the form and send it by email to sescn.tech@michelin.com.
· If you wish to exercise your rights with respect to your personal data that Michelin treats as a data processor, you must contact the customer to obtain information about your rights and how they can be exercised.
· If you are authorized by our customer to request the assistance of Michelin as a processor to fulfill the exercise of a right benefiting a data subject, you must contact us via the following email address: sescn.tech@michelin.com.
The general rule is that we do not request the payment of any fee. Access to your personal data (or the exercise of other rights) is free. However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. We may also refuse to grant your request in these circumstances.
We may ask you for specific information to help us confirm your identity and guarantee your right to access your personal information (or to exercise your other rights). This is a security measure to ensure that personal data is not disclosed to people who are not entitled to know it. We may also contact you to ask for more information about your request so that we can respond to you quicker.
We try to respond
to all justified requests within a month. We can
occasionally need more than one month if your
request is particularly complex or if you have made several requests. In this
case, we will notify you and keep you informed of the progress of your request(s).
We are committed to protecting and respecting your privacy. However, if you are 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 at sescn.tech@michelin.com
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.
Michelin undertakes that your personal data will not be accidentally lost, used, or accessed without authorization, altered or damaged. Michelin has procedures in place to deal with any suspicion of personal data breach and will notify its customers and any relevant supervisory authority of any violation when we are legally or contractually obliged to do so.
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: March 2023