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 and you.
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.
Sensitive Personal Information
While we do not request sensitive personal information, we do have sections on our websites where you can submit additional information, for example, when you submit a review. If you submit information on these free text sections, only submit information you are comfortable providing and always bear in mind that it may be sensitive information. If you submit reviews or feedback for our website, please remember that this information will be visible to others users of our website.
5. Marketing Communications
When you sign up to receive any of our newsletters or marketing communications we will use the information you provide us, usually just your name and email address, to enable us to send you our newsletters, promotions and other communications you’ve requested. We will process your personal information for email marketing purposes based on your consent.
Don’t’ worry, if you decide at any point that you no longer want to receive these emails, you can unsubscribe at any time. There are a number of ways you can do this: (i) there is always an unsubscribe option at the bottom of each marketing communication we send to you; and (ii) you can also contact us by email or letter using any of the contact details set out in this privacy policy. If you withdraw your consent, we will stop sending you our newsletters and promotions and other communication as requested.
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 36 months, we will remove your details from our database. There’s nothing stopping you from subscribing again at any time.
From time to 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 is necessary for the legitimate interest of our business in developing our products and services and growing our business.
6. 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 or services we provide. We also work closely with third parties (including, for example, business partners, technical service providers, payment services, analytics providers, such as Google Analytics and search information providers) and may receive information about you from them. The legal basis for this processing is our legitimate interests in 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 platforms. It also helps us to provide the best infrastructure for your online experience. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website, products and services.
- as mentioned above, we collect information using cookies stored on your device about how you use our website, digital products and services. You can read our Cookie Policy here.
- our website may enable you to share your experience and connect with us through third party social networks such as Facebook and Twitter. We may collect this information from our social media sites, including likes, shares and tweets, and about the content on social networking sites. We do not control the privacy of the information you provide on social media networks and the privacy policies of those social media networks will apply when using their services.
7. Where we store your personal information
All information you provide to us is stored on secure servers hosted by the LinkbyNet Group (see section 9 below for further information).
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.
8. Sharing your personal information
We only share your personal information 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 select 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.
We may also share your personal information with third parties:
- In the event that we sell or transfer any business or assets, in which case we may disclose your personal information to the prospective purchaser or recipient of such business or assets.
- 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. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- In order to manage risks and legal disputes and obtaining professional legal advice. This disclosure will be on a confidential basis and only to our professional advisors who are under a duty of confidentiality.
9. 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 information 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 information 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 information from the European Union or European Economic Area. A copy of these rule are available on written request.
Whenever there is a transfer of personal information out of the EEA, we ensure a similar degree of protection is afforded to that personal information by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission;
- where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe; or
- where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
In relation to web hosting provided by LinkbyNet, information can, in some cases, be transferred outside of the EEA by the companies of the LinkbyNet Group in relation to support operations that will be made from Canada (a country with a sufficient level of protection), Vietnam and Mauritius. These transfers are governed by the LinkbyNet Group’s Binding Corporate Rules.
10. 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 4 above. While we do everything we can to comply with these retention periods, if there is a legal, accounting or tax reason why the information is to be held for longer, we will only retain the information for as long as necessary to satisfy that legal, accounting or tax reason.
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 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.
11. 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:
- be informed
- access your information
- correct your information
- delete your information
- restrict processing
- transfer information
- object to processing
a. The right the 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.
b. The right of access to 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.
c. 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.
d. The right to delete your information
You have the right to request the deletion or removal of your personal. There are limited circumstances in which you can request deletion of you information, these include, where the information is no longer necessary for the purpose for which we originally collected or processed it and where you have withdrawn your consent to the processing by us. If you would like further information on your right to deletion, please just ask.
e. The right to restrict processing
In some circumstances, you also have the right to restrict or suppress the processing of your personal information. If you request us to suppress your personal information, we will suspend any further processing of it.
f. The right to transfer information
If you want to move or transfer your personal information to a different service provider, you have the right to have your information transferred to another person.
g. The right to object
You have the right to ask us not to process your personal information where we are relying on a legitimate interest and there is something which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
If you want to exercise your any of your rights detailed in this Privacy Policy, you can do this at any time by emailing us at legal.general@michelin.com.
You can also find further information on your data protection rights from the Information Commissioner’s Office (the “ICO”) at www.ico.org.uk.
12. What can you do if you’re not happy with how we use your information
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 in the following ways:
- email us at legal.general@michelin.com;
- send us a letter addressed to the Data Protection Officer, Michelin Tyre plc, Campbell Road, Stoke on Trent ST4 4EY.
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 ICO – further information can be found at https://ico.org.uk/concerns/.
13. 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.
14. 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 we have your email address, we may notify you of any changes by email.
Policy last reviewed: May 2018
