PRIVACY NOTICE.

Last Updated: 11/30/2023

This Privacy Notice explains how any personal information we collect when you use our website or digital services, or that you provide to us, will be processed by us.

Please read the following Notice carefully to understand our views and practices regarding your personal information and how we will treat it.

If you are a resident of California or Nevada, please see our Additional U.S. Privacy Disclosures available here: https://connectedfleet.michelin.com/en-us/additional-privacy-disclosures/ for additional privacy disclosures that apply to you.

1. Who we are and how we can be contacted
2. About our Data Protection Officer
3. Other policies and information we encourage you to read
4. Information we may collect from you
5. Marketing Communications
6. Information we collect about you from other places
7. Sharing your personal information
8. International transfers of personal data
9. How long will personal information be kept by us
10. Rights under data protection legislation
11. What you can do if you’re not happy
12. About Data Security
13. Changes to our Privacy Notice

• Who we are and how we can be contacted

Our full company name is NexTraq, LLC (“Michelin Connected Fleet”, “MCF”, “we”, “us”, or “our”) and when you use our website and our services directly we act as a Data Controller.

If you need to contact us you have a number of options, you can:

• email us at: GDPR@masternaut.com
• You can send us a letter addressed to:
  MICHELIN Connected Fleet Data Protection Officer - Djamel Souici

Priory Park

Great North Road, Aberford

Leeds

LS25 3DF

United Kingdom

• About our Data Protection Officer

We have a data protection Privacy Department who deals with all aspects of personal data at MCF:

MICHELIN Connected Fleet Data Protection Officer - Djamel Souici

Priory Park

Great North Road, Aberford

Leeds

LS25 3DF 

United Kingdom

You can also contact our Privacy Department by sending an email to: GDPR@masternaut.com 

• Other policies and information we encourage you to read

While this Privacy Notice 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:

• Additional privacy policies

This is our main privacy Notice for your use of website and digital services and products offered by MCF.  However, there may be additional information in privacy policies for specific digital products and services.  Please read these policies when you register or subscribe to these products and services.

• Our Cookie Notice

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 Notice which explains our use of cookies and the purposes for which we use them. We encourage you to read our Cookie Notice here: https://connectedfleet.michelin.com/en-us/cookie-notice/.

• Terms of use

Our Website Terms of Use provides the terms on which you may make use of our websites and should be read alongside this Privacy Notice.  You can read our Website Terms of Use here: https://connectedfleet.michelin.com/en-us//website-terms-of-use/.

• Linked platforms

Our site may contain links to and from our third-party websites, plug-ins, and applications, including the websites and digital platforms of our partner networks, advertisers, affiliates, and social media pages.  If you follow a link to any of these websites, please note that except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties.  To learn more about the personal information practices of third parties, please check their respective privacy policies before you submit any personal information to these websites.

• 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; and
• The legal basis that we will rely on to process information collected.

We may collect and hold the information about you in the table below.  If you reside in the European Economic Area (“EEA”) or the United Kingdom (“UK”), the lawful basis of processing is set out in the “Lawful basis for processing” column below. In other jurisdictions, such as Canada, the primary legal basis for the collection and use of your personal information is your express or implied consent.  However, where the processing of personal information involves sensitive personal information in Canada or involves profiling you, collecting your geolocation or using technologies to identify you, we will obtain your explicit consent. In these jurisdictions, you may opt-out of the use of your personal information if it is not necessary to communicate with you, to provide you with the products and services you request, to meet our legal obligations or to protect our rights.

• 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.

• 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 and our affiliates business purposes only.

• Sensitive Personal Information

Certain of the personal data elements we collect may be classified as “sensitive” under certain privacy laws, such as account name and password, precise geolocation data, financial account number, and credit or debit card number plus expiration date and security code (CVV). While we generally do not request other types of 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 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 other users of our website.

• Children and Personal Information

This website is not intended for use by children, and we do not knowingly collect data relating to children.  If we become aware that we are holding any information about children under the age of 14, we will take any actions necessary to comply with data protection legislation, including if appropriate, deleting the information.  If you become aware that your child (under 14) has provided their personal information to us, without your consent, please let us know as soon as possible by emailing GDPR@masternaut.com so that we can take appropriate action.

• Segmentation and Targeting

As part of our services, MCF may need to create user groups in order to better target the offers and communications sent.

The segments or profiles are produced on the basis of information held by MCF or the companies of the Michelin group (account data, navigation data, purchase data, declarative data) or information collected in the context of our relations with partners (e.g., social networks, etc.).

MCF undertakes not to use, for segmentation and targeting purposes, personal data likely to reveal racial or ethnic origin, political opinions, religious or philosophical convictions or trade union membership, as well as genetic, biometric, health data or data relating to the sexual life or sexual orientation of a natural person, in accordance with applicable laws.

• Complying with Legal Obligations

We will process your personal information  when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of personal information  to protect our rights, and is necessary for our legitimate interests to protect against misuse or abuse of our websites, to protect personal property or safety, to pursue remedies available to us and limit our damages, to comply with a judicial proceedings, court order or legal process, and/or to respond to lawful requests.

• Marketing Communications

Subject to local legal requirements, you will receive marketing communications or newsletters from us only (i) if you wish it, (ii) if you are one of our customers, provided that this communication will concern similar products or services or if (iii) this communication is linked to your business activity.

You can unsubscribe or stop direct marketing from us at any time by either (i) clicking on the unsubscribe option at the bottom of each marketing communication we send to you; and (ii) contacting us by email or letter using any of the contact details set out in this Privacy Notice.

Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as information about your subscriptions or event registrations, service announcements or security information.

If we have a legal basis to send you marketing communications, we will generally send you those communications until you choose to unsubscribe from receiving them.

From time to time we may also use your personal information, including your Usage and Device Data (as defined below), to conduct marketing research, advertise to you, provide personalized information about us on and off our websites, and to make online suggestions and recommendations to you about goods or services that may be of interest to you. Unless local law requires us to obtain your consent, we will use your personal information, including your Usage and Device Data, in this way as it is.  This is necessary for the legitimate interest of our business in developing our products and services and growing our business. Please also view "Rights under data protection legislation" below to learn how you can control how your personal information is processed by MCF for marketing purposes.

• 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:

• In providing our services, we may collect personal data about our customers’ end users or other individuals, or we may collect personal data on our customers’ behalf (all of which we call “Customer Data”). We collect and process Customer Data on behalf of our customers, and in accordance with our agreements with the customers. We recommend you read the privacy Notice of the respective customer to understand their processing of your personal data and to exercise any available rights. With regards to our processing of your personal data, please review the choices that may be available to you in the “Rights under data protection legislation” section below.
• 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, sub-contractors in technical, payment services, analytics providers, search information providers and credit reference agencies) and if permitted by you or as permitted by applicable law, we may receive information about you from them.  Subject to local legal requirements, the legal basis for this processing is our legitimate interests, namely monitoring and improving our website, products and services.
• We and our third-party providers may collect information from our web servers’ logs, for example information about your computer, such as your IP address, operating system and browser type.  We and our third-party providers may also collect information about how you interact with our services, including on the searches you carry out on our website and your interaction with communications we send you, for example, when you open email communications, interact with/message using our chat function, or interact with one of our automated tools (“Usage and Device Data”).  This information is used by us and our third-party providers for system administration, for product improvement (including training and refining automated tools leveraging artificial intelligence), and to analyze how people are using our websites and digital platforms.  It also helps us to provide the best online infrastructure for your online activities.  Subject to local legal requirements, which may require explicit consent, 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 or other similar technologies stored on your device about how you use our website, digital products and services.  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 personalized service to you.  You can read our Cookie Notice here: https://connectedfleet.michelin.com/en-us/cookie-notice/.
• 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.

• Sharing your personal information

We may share your personal information with the following:

• Within the Michelin Group – MCF is part of 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 Notice.  In particular, your contact data (email address, interests) can be shared with Michelin Group companies in order to know you better and personalize the experience that Michelin companies can bring you and send you marketing offers and communications related to the newsletters to which you have subscribed.
• Service Providers - MCF may share your personal information with selected service providers that MCF 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.
• We may also share your personal information with third parties:

(i) For legal reasons:

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 MCF or the Michelin Group, our customers, or others.  In this context, we may disclose your personal information to our professional advisors who are under a duty of confidentiality.

(ii) For business transaction or reorganization purposes:

We reserve the right to transfer any information we collect in the event we sell or transfer all or a portion of our business or assets (including any shares in the company) or any portion or combination of our products, services, businesses and/or assets.  Should such a transaction occur (whether a divestiture, merger, acquisition, bankruptcy, dissolution, reorganization, liquidation, or similar transaction or proceeding), we will use reasonable efforts to ensure that any transferred information is treated in a manner consistent with this Privacy Notice.

(iii) On the basis of your consent:

Third parties can collect information about you on our website, products or services via cookies or similar technologies, in order, for example, to provide certain technological features or personalized ads, or for profiling purposes.  These cookies will be accepted by you in accordance with our Cookie Notice available here: https://connectedfleet.michelin.com/en-us/cookie-notice/. 

• International Transfers of Personal Data

MCF carries out operations in a number of countries both inside and outside the EEA and is part of the Michelin Group which is an international group with databases in the various countries in which it operates.  MCF may transfer your personal data within the group to one of its databases or to its external partners located outside of your home country.  We take steps to ensure that our transfers of data are lawful by, for example, entering model contracts approved by the European Commission, called the Standard Contractual Clauses, through Binding Corporate Rules or on the basis of specific consent or as otherwise permitted by applicable law.

• 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.

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 (such as applicable statutes of limitation).

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.

After expiry of the retention periods, your personal information will be deleted. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of the data.

• Rights under data protection legislation

The data protection legislation of your jurisdiction may provide you with certain rights when it comes to the processing of your personal information. The rights listed below may not all apply to you as your rights with regards to personal information depend on your jurisdiction.  While some of these rights listed below apply generally, certain rights apply only in limited cases or under your applicable local law.  They may or may not apply to you depending on your jurisdiction.

• 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 (data portability)
• The right to object to processing 
• The right to give instructions beyond your death

If you are a resident of California or Nevada, please see the “Additional U.S. Privacy Disclosures” for more information on the privacy rights that may be afforded to you.

The right to be informed  

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

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 detailed in this Privacy Notice.

The right to delete your information

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 circumstances 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 (data portability)

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

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.

The right to not be subject to a decision based solely on automated processing

The right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"); Automated Decision-Making currently does not take place on our websites.

The right to withdraw your consent

To the extent we base the collection, processing and sharing of your personal information on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

The right to define the outcome of your personal information after your death

The right to give us instructions on what we wish that we do with your personal information after your death.  We will register it and if we heard that such event occurred, we will comply with your instructions.

For further information on your rights

You can find further information on your data protection rights from the privacy authority of your jurisdiction.

To exercise your rights, please contact us in accordance with our contact details in the section below. We try to respond to all legitimate requests and will contact you if we need additional information from you in order to honor your request.

• What can you do if you’re not happy

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: GDPR@masternaut.com 
• MICHELIN Connected Fleet Data Protection Officer - Djamel Souici

Priory Park

Great North Road, Aberford

Leeds

LS25 3DF 

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 may also make a complaint to the privacy authority of your jurisdiction.  For example, if you are Canadian can make a complaint to the Office of the Privacy Commissioner of Canada – further information can be found at https://www.priv.gc.ca/en/ or with the privacy authority of your jurisdiction.

• About Data Security

MCF has implemented reasonable and appropriate technical and organizational measures designed to protect the privacy, security, and integrity of your personal data.

• Changes to our Privacy Notice

We will update this Privacy Notice from time to time.  When we make changes to this Privacy Notice, we will change the “Last Updated” date within this Notice.  If we make material changes to this Privacy Notice we will notify you by updating the “Last Updated” date or through other appropriate communication channels.  All changes shall be effective from the date of publication unless otherwise provided in the notification.