PRIVACY POLICY

Summary

Michelin is committed to protecting your personal information and being clear and transparent about what information we collect and how we use it. This policy explains how any personal information we collect or that you provide to us when you use our website or when you order products or services, 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 process it.

 

1 - Who we are and how we can be contacted

2 - Our websites covered by this privacy policy

3 - About our Privacy Department

4 - Other policies you should read

5 - Information we may collect from you

6 - Marketing Communications

7 - Information we collect about you from other places

8 - Where we store your personal information

9 - Sharing your personal information

10 - International Transfers of Personal Data

11 - How long with personal information be kept by us

12 - Your rights under data protection legislation

13 - What you can do if you're not happy with how we use you information

14 - About Data Security

15 - Changes to our Privacy Policy

1. Who we are and how we can be contacted

Our full legal name is Michelin Travel Partner ("Michelin") and, when you use our website or services, we are the data controller. If you need to contact us you have a number of options:

 

   You can contact us by email at privacy.tp@michelin.com

   You can also contact us by mail at the following address: Privacy Department: 27, cours de l'Ile Seguin, 92105 Boulogne-Billancourt Cedex, France

   You can also contact us using our contact form on our website here.

   You can also contact us by telephone on +33 (0)1 55 19 57 00/01.

2. Our websites covered by this privacy policy

The information set out in this policy is applicable to the website "Michelin GUIDE PRO" published by Michelin and available here and via the following extensions (.de, .at, .be, .hr, .dk, .es, .fi, .fr, .gb, .gr, .hu, .it, .ie, .is, .lu, .no, .pl, .pt, .nl, .cz, .se, .ch, .us).)

3. About our Privacy Department

While everyone at Michelin is committed to protecting and respecting your privacy, we have a privacy department who deals with all aspect of personal data at Michelin. You can contact them, by sending an email to privacy.tp@michelin.com.

4. Other policies and information we encourage you to read

While this Privacy Policy contains all the information you need on how we collect and use your personal information on our websites, there is information in some other places which we encourage you to read.

 

Our cookie policy

When you use our website and other digital products and services provided by us, information can 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 explains our use of cookies and the purposes for which we use them. We encourage you to read our Cookie Policy.

Linked platforms

Our site may contain links to and from our websites and digital platforms of our partner networks, advertisers, affiliates and social networks. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

Third party partners

We may share your personal information with third party partners according to the terms and for the purposes described in section 9 of this policy. The processing they implement as data controllers are governed by their own privacy policies and that we do not accept any responsibility or liability for these policies. Please review these policies before providing any personal information when ordering.

5. 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

 

Data collected

Purpose/Activity

Type of Data

Lawful basis for processing

Retention period

Information you provide us to place an order ("Order Data")

We process this information only to process your order

Full name, role, telephone number, email address, shipping address, billing information.

The performance of the agreement between you and us is the legal basis for processing Order Data.

These data will be deleted within 10 years

Information you provide to us when you request our customer department services ("Customer service data")

We process this information to provide you with our after-sale service or answer to your request or claim.

Full name, telephone number, email address, order details

The legal basis for such processing is the performance of the agreement between you and us or our legitimate interest to manage disputes.

Information will be deleted after the processing of your request or claim, and in any case, after 5 years to manage potential disputes

Information you provide to pay your order (" Payment data ")

We process this information only to process the payment of your order.

Full name, credit card holder, credit card number, expiration date, cryptogram

The legal bases for such processing are the execution of the agreement between you as well as the respect of the legal obligations (art.133-24 of the monetary and financial code)

These data are kept by a secure payment service provider the time required for the processing of the payment plus 15 months to manage any disputes.

Information you provide to us for additional information by subscribing to one of our newsletters or commercial communications ("Marketing Data")

For more details, please refer to section 6 of this policy.

Marketing data are processed for the purpose of sending you marketing communications and / or newsletters

We will ask for your name and e-mail address in order to send you the requested communications

The legal basis of this processing is your consent (for example if you are a prospect) or our legitimate interest in communicating about our products or services (if you are already a customer and if they are similar products or services).

Your information will be kept for a period of 3 years from their collection or after the last contact of your part.

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, tailor our services to them or answer to your request.

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 data, 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 section, 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 other users of our website.

Minority and personal information

Our website is not intended for minors and we do not intentionally collect information about minors. If we realize that we hold any information about a minor (as defined by the applicable regulations, i.e. an individual under 15 years of age in France), we will take all necessary actions to comply with the regulations applicable and especially, if needed, the deletion of this information. If you are aware that your minor child has provided us with personal information without your permission, please contact us as soon as possible at privacy.tp@michelin.com so that we can take appropriate action.

6. Marketing Communications

You will only receive marketing communications or newsletters from us (i) if you wish, or (ii) if you are already one of our customers, provided that such communication relates to similar services or products.

In order to do so, we will use the information you provide us, usually just your name and email address.

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 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 36 months, we will remove your details from our database. There's nothing stopping you for subscribing again at any time.

In order to tailor the communications that we send to you and to make recommendations and suggestions on goods or services that may interest you, we may use your Order Data and your MICHELIN Guide Data. This processing is based on your consent.

7. Information we collect about you from other places

We may process information about you from other sources, especially as part of the questionnaire to collect or update data about you which are included in the MICHELIN Guide ("MICHELIN Guide data").

 

As mentioned on such questionnaire, the legal basis of this processing is our legitimate interest in managing quality and improvement of our website, products and services.

 

We may process information from our web servers' logs, for example information about your computer, such as your IP address, operating system and browser type ("Usage and Device Data"). This information is used by us for system administration and to understand 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.

 

As mentioned above, we collect information ("Behavioral Data") using cookies or other similar technologies stored on your device about how you use our website, digital products and services (especially about your display and search preferences and how you surf / use our websites). Cookies contain information that is transferred to your computer's hard drive. They help us to improve our websites and deliver a better and more tailored service to you. You can read our Cookie Policy.

 

We will be able to cross the Behavioral Data, the Marketing Data, the MICHELIN Guide Data and the Order Marketing Data to send you communication, marketing or commercial communications (especially basket reminders), as well as personalized newsletters.

 

The legal basis of this processing is your consent or, where applicable, our legitimate interest in monitoring and improving our website, products and services.

8. 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.

9. Sharing your personal information

The recipients of your personal data are limited exclusively to the people who have a need to know such information to perform their responsibilities.

We may share your personal data as follows:

 

       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.

 

       To subcontractors

Michelin may share your personal data with subcontractors that Michelin may use to process your request or provide the services. These subcontractors are contractually obligated to keep the personal data they may have received confidential and secure and to use your personal data only on the basis of our instructions.

 

       To third parties

i.        For the execution of your order

When you place an order on our site, we transfer some of your personal information to the companies with which we work and who manufacture and deliver the ordered products.

These companies are today:

- Bragard, 50 Rue Léo Valentin, 88000 Épinal, rgpd@bragard.com, for the jackets., for the menu and ticket holders and business cards

- Brand Addition, Broadway, Trafford Wharf Road, Manchester, M17 1DD, dataprotection@brandaddition.com, for plaques, stickers, trophies, chalkboard, pens, pack pens and notebook

- Silkscreen Bernard Delannois, rue Volentaires de Guerre 4, 7711 Dotti, fa301708@skynet.be for personalized guides.

Only the data strictly necessary for the execution of the order in question (in particular the name, the first name, the telephone number, the email address and the delivery address) are transferred to these third party partners.

 

ii.       For legal reasons

If we are compelled 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 contract; or to protect our rights, our property or the safety of the Michelin Group, its customers or other partners.

 

iii.      On the basis of your consent

Third parties may collect information about you from our website, our products or services via cookies or similar technologies, for example to track navigation on the website and to perform statistical. These cookies will be processed according to our Cookie Policy. You can take thoughts here.

10. 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 (EEA). By clicking on BCRs, you can find the details of these rules.

Transfers of data outside the group are governed either by the BCR of our processor either 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.

11. 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 5 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 unauthorized 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 anonymize 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.

12. Your rights under data protection legislation

Data protection legislation provides you with certain rights when it comes to the processing of your information.

 

 

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. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your information.  You can also exercise the right at any time by contacting us at privacy.tp@michelin.com

For more information about your privacy rights

You can find further information on your data protection rights from the CNIL at www.cnil.fr.

13. 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 in the following ways:

 

       You can send us a letter addressed to privacy.tp@michelin.com

       You can also contact us using our contact form

 

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 CNIL - further information can be found at www.cnil.fr.

14. 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.

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, except for legal reasons.

Michelin ensures that your personal data are not altered, damaged or accessed by unauthorized third parties.

15. 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.