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Last Updated: 11/30/2023

  • Scope of Disclosures

For Nevada Residents: Chapter 603A of the Nevada Revised Statutes permits Nevada residents to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please email GDPR@masternaut.com.

For California residents: These Additional U.S. Privacy Disclosures (the “U.S. Privacy Disclosures”) supplement the information contained in our Privacy Notice (available here: https://connectedfleet.michelin.com/en-us/privacy-notice/) providing additional information about how NexTraq, LLC (“MICHELIN Connected Fleet”, “MCF”, “we”, “us”, or “our”) processes personal data and apply solely to individual residents of the State of California (“data subjects” or “you”).

These U.S. Privacy Disclosures provide additional information about how we collect, use, disclose and otherwise process personal data of individual residents of the State of California in connection with our websites (the “Sites”) and other websites we own and operate that link to these U.S. Privacy Disclosures, and the related content, platform, services, products, and other functionality offered on or through our services (collectively, the “Services”).

Unless otherwise expressly stated, all terms in these U.S. Privacy Disclosures have the same meaning as defined in our Privacy Notice.

Personal Data

When we use the term “personal data” in these U.S. Privacy Disclosures, we mean any data or information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household or any other data or information that constitutes “personal data”, “personal information,” or “personally identifiable information.”

Personal Data Collection

We collect various categories and types of personal data from a variety of sources and for a variety of purposes. We also disclose personal data to a number of recipients.

In the last 12 months, we may have collected the following categories of personal data:

  • Identifiers, such as name, email address, telephone number, address, zip code, account username and password, or other similar identifiers.
  • California Customer Records (Cal. Civ. Code § 1798.80(e)), such as credit/debit card information, bank account information or other payment information.
  • Commercial Information, such information about products or services purchased or considered, whether you used a particular promotion, information about the third-party dealer from whom you purchased a MCF product (if applicable), and information about your use of the Services.
  • Internet/Network Information, such as your browsing history, log and analytics data, search history and information regarding your interaction with our website.
  • Geolocation Data, such as information about your physical location collected from geolocation features on your device, and location information, such as vehicle location, that is provided in connection with the Services.
  • Sensory Information, such as pictures or video content you provide or upload in connection with the Services, and the content and audio recordings provided in connection with the Services.
  • Professional/Employment Information, such as job title, department, employer or business, and trade or professional association membership information.
  • Other Personal Data, such as information and content you post to the Services and other information you submit to us, including inquiry and communication information when you contact us.  We may also collect certain information about your vehicle, such as VIN number, Department of Transportation (DOT) code, vehicle type, make, model and registration information, and tire depth and size information.
  • Inferences, including information generated from your use of the Services reflecting predictions about your interests and preferences.

For more information about our collection of personal data, the sources of personal data, and how we use this information, please see Section 4 (“Information we may collect from you”) and Section 6 (“Information we collect about you from other places”) of our Privacy Notice.

Disclosure of Personal Data

As described in Section 7 (“Sharing of your personal information”) of our Privacy Notice, we disclose personal data to a variety of third parties for business purposes or otherwise make available personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”), as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. Some of these practices may involve the “sale” of personal data, or the sharing or processing of personal data, for the purpose of facilitating targeted advertising. Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal data or the processing of personal data for purposes of targeted advertising (as described in the “Your Privacy Rights” section below).

In the previous 12 months, we have disclosed all of the categories of personal data we collect, explained above, to third parties.

In the previous 12 months, we have also sold or shared for targeted advertising purposes the following categories of personal information to third parties, including third-party ad networks, social networks and advertising partners, subject to your settings and preferences and your Right to Opt Out: Identifiers, Commercial Information, Internet / Network Information, and Inferences.

In addition, please see our Cookie Notice to learn more about how third-party advertising networks, social media companies and other third-party businesses collect and disclose your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our Services or otherwise engage with us.  

Sensitive Information

The following personal data elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”):

  • Account name and password; 
  • Precise geolocation data; and
  • Financial account number and/or credit/debit card number plus expiration date and security code (CVV).

As described in our Privacy Notice, we use account name and password, precise geolocation data, as well as payment card information to provide certain of our products and services. 

We do not sell sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.

Deidentified Information

We may at times receive, or process personal data to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

Your Privacy Rights

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

The Right to Know

The right to confirm whether we are processing personal data about you and to obtain certain personalized details about the personal data we have collected about you, including:

  • The categories of personal data collected;
  • The categories of sources of the personal data;
  • The purposes for which the personal data were collected;
  • The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom this personal data were disclosed;
  • The categories of personal data sold (if any), and the categories of third parties to whom the personal data were sold; and
  • The categories of personal data shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for these purposes.

The Right to Access & Portability

The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

The Right to Correction

The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.

The Right to Opt Out of Sales or Sharing for Targeted Advertising Purposes

The right to direct us not to sell or share personal data for certain targeted or cross-context behavioral advertising purposes. 

The Right to Control Over Automated Decision-Making / Profiling

The right to direct us not to use automated decision-making or profiling for certain purposes

The Right to Limit the Use and Disclosure of Sensitive Information

The right to direct us to limit the use of your sensitive personal information to certain purposes.

The Right to Request Deletion

The right to request the deletion of personal data that we maintain about you, subject to certain exceptions.

You also have the right not to receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, please note that the exercise of the rights described above limits our ability to process personal data (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner. In addition, the exercise of the rights described above may result in a different price, rate, or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law. 

How to Exercise Your Privacy Rights

Please submit a request by:

  • Filling out our online form; or
  • Calling 1-888-971- 3804.

For certain requests, we will need to verify your identity and confirm you are a resident of the State of California before processing your request.  In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests to include name, email address, and state of residency. Although we try to limit the personal data collected in connection with a request to exercise any of the above rights, certain requests may require us to obtain additional personal data from you.  In certain circumstances, we may decline a request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of the State of California.

To Exercise the Right to Opt Out of the Selling, Sharing or Processing of Personal Data for Targeted Advertising Purposes

We may sell or share personal data (including Identifiers, Commercial Information,  Internet/Network Information, and Inferences) to certain third-party ad networks, social networks and advertising partners to deliver targeted advertising (also known as “cross-context behavioral advertising”) and personalized content to you on our Sites and Services, on other sites and services you may use, and across other devices you may use, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. 

The third parties to whom we sell or share personal data may use such information for their own purposes, in accordance with their own privacy statements, which may include reselling or sharing this information to additional third parties. 

To facilitate these targeted advertising purposes, we and our third-party providers use cookies and related technologies to collect personal data about users of our Sites and Services. To exercise your right to opt-out as it relates to the use of cookies and related technologies that involve the sale of personal data or the use of personal data for targeted advertising purposes on our Sites and Services, please click to adjust your cookie preferences by unchecking the “Targeting and Advertising Cookies” option. 

Please note these cookie options may be unchecked or opted out by default. In addition, this opt-out tool is device and browser specific, so you will need to change your preferences on each device and browser you use to interact with the Site or Service you are visiting. 

You can also opt out of cookie-based sales by businesses that participate in the DAA’s CCPA Opt-Out Tool by visiting https://www.privacyrights.info/. In addition, you may follow the other steps set forth in our Cookie Notice (available here: https://connectedfleet.michelin.com/en-us/cookie-notice/) to further exercise control over cookies and related technologies. Lastly, you may exercise your non-cookie-related rights by following the instructions provided at the beginning of this “How to Exercise Your Privacy Rights” section. 

Authorized Agent

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Data Retention

For information on our data retention practices, please see Section 9 (“How long will personal data be kept by us?”) of our Privacy Notice.

Minors Under Age 16

We do not sell the personal data of consumers we know to be less than 16 years of age.

If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal data and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative).

Updates to These U.S. Privacy Disclosures

We will update these U.S. Privacy Disclosures from time to time.  When we make changes to these U.S. Privacy Disclosures, we will change the “Last Updated” date at the beginning of these U.S. Privacy Disclosures.  If we make material changes to these U.S. Privacy Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels.  All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with these U.S. Privacy Disclosures or other privacy-related matters, please send an email to GDPR@masternaut.com.

Alternatively, inquiries may be addressed to:

MICHELIN Connected Fleet Data Protection Officer - Djamel Souici

Priory Park

Great North Road, Aberford

Leeds

LS25 3DF