We do update this Policy from time to time so please do review this Policy regularly.
[Updated 09/02/2024]
Summary
MICHELIN Connected Fleet is committed to protecting your personal information and being clear and transparent about what information we collect and how we will use it. This policy 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 policy carefully to understand our views and practices regarding your personal information and how we will treat it.
In some countries we may provide additional information about the use of your personal data by us and our group companies which should be read alongside this information.
- Who we are and how we can be contacted
- About our Data Protection Officer
- Other policies and information we encourage you to read
- Personal information we collect from you
- Marketing Communications
- Sharing your personal information
- International Transfers of personal information
- How long will personal information be kept by us?
- Your rights under data protection legislation
- What can you do if you’re not satisfied with how we use your information?
- Data Security
- Changes to our Privacy Policy
1. Who we are and how we can be contacted
Masternaut Limited (trading as MICHELIN Connected Fleet)
Registered Office: Priory Park, Great North Road, Aberford, Leeds, West Yorkshire, LS25 3DF, United Kingdom
Registered Number: 7848318 (England and Wales)
We also have legal entities in other countries where we operate, where relevant you can find the details on our website.
2. About our Data Protection Officer
While everyone at MICHELIN Connected Fleet is committed to protecting and respecting your privacy, we have a Data Protection Officer. To exercise your rights regarding your personal information, or if you have questions regarding this Privacy Statement or our privacy practices, please mail us at:
MICHELIN Connected Fleet Data Protection Officer - Djamel Souici
Priory Park
Great North Road, Aberford
Leeds
LS25 3DF
Email: GDPR@michelinconnectedfleet.com
3. 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:
- Additional privacy policies
This is our main privacy policy for your use of our website. Where we process personal information for our customers as part of the provision of services to those customers, the processing will usually be governed by the terms of that contract and not this privacy policy. Additional information relating to this processing and your rights in relation to it is available from our customer, or, where we are required to provide information directly to you, in the additional disclosures for your jurisdiction.
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 here: https://connectedfleet.michelin.com/cookie-notice/
Our website terms of use tell you the terms on which you may make use of our websites and should be read alongside this Privacy Policy. You can read our website terms of use here: https://connectedfleet.michelin.com/legal-notice/.
Our site may contains links to and from third-party websites, plug-ins and applications, including the websites and digital platforms of our partners, 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 Policy, this Privacy Policy 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.
4. Personal information we 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.
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Data collected
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Purpose/Activity
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Type of Data
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Lawful basis for processing
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Information you give to us when you enter a competition or promotion (“Competition Data”).
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To enable us to send you further information about the competition or a prize if you are the competition winner. Unless we state otherwise when we collect your information, we will only use this information for managing and administering the competitions or promotions.
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Competition Data might include, for example, your name and e-mail address.
If you win a prize, we may request your full address to enable us to send you your prize
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The performance of an agreement between you and us to enter the competition or promotion.
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Information you provide to us when you complete a survey, respond to a questionnaire, or submit a review or feedback (“Review Data”).
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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. If such functionality is available, feedback and reviews may be disclosed on the Website with some personal information. In such case, you will be informed.
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Information may include your full name, your email address and other personal data requested.
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Our legitimate interests in the monitoring and improvement of our products and services to our customers and users and in the sharing of customer experience with web users.
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If you register for any of our digital products or services via an account, we will request information to enable us to identify you and provide the products and services to you (“Account Data”).
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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.
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Account Data will include your full name and email address. We may also ask you to set a password so you can securely log on to your account.
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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.
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Audio/video content, including pictures you provide or upload in connection with the services, and the video content and audio recordings from vehicles that are connected through our services (“Audio/Video Data”).
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This information is used to enable us to provide the services to our customers.
Although we analyze video content and audio recordings to identify certain objects or characteristics contained within each, we do not use video content or audio recordings for purposes of recognizing or identifying individuals who may appear in such content or recordings.
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Audio/Video Data may include pictures of video content of you, and audio recordings.
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We act as a data processor on behalf of our customers who are responsible for determining the lawful basis for processing.
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Vehicle and driver’s license information, including location of the vehicle, VIN number, vehicle type, make, model and registration information, and tire depth and size information when you purchase certain products from us or register for the services (“Vehicle and Driver’s License Data”).
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This information is used to enable us to provide the services to our customers.
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Information may include driver’s license information, location of the vehicle, VIN number, vehicle type, make, model and registration information, and tire depth and size information.
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We act as a data processor on behalf of our customers who are responsible for determining the legal basis.
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Information you provide us when you communicate with us, e.g., by email or contact us form via our websites or through live or automated chat functions on our website (which functions may leverage artificial intelligence), request user support, sign up for an event or webinar, or download certain content (“Contact Data”).
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This information is used to enable us to respond to or to follow up on your comments, queries, or questions, and may also be used by us and our third-party technology providers to identify and facilitate potential product improvements or future product developments (including training and refining automated tools leveraging artificial intelligence). This information may also be used by us to register you for an event or webinar.
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Information may include your full name, your email address and other personal data you provide us to enable us to deal with your communication or registration.
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Our legitimate interests in assisting you, answering your communications, improving our offerings based on our interactions and your feedback, and registering you for an event or webinar as the legal basis for processing Contact Data.
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If you attend an event, we may scan your attendee badge which will provide us with your name, title and company name, address, country, phone number, and email address (“Attendee Data”).
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This information is used to enable us to log your attendance at an event, to provide us with analytics on event attendees and subject to required consent may allow us to contact you after the event.
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Information may include your full name, title and company name, address, country, phone number, and email address.
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Our legitimate interests in registering your attendance at an event, recording analytics data and following up with attendees as the legal basis for processing Attendee Data, subject to any consent required.
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If you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name, and time and date of arrival (“Visitor Data”).
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This information is used to enable us to track visitors to our office for purposes of security and health and safety.
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Information may include your name, email address, phone number, company name, and time and date of arrival.
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The legal basis for this processing is legitimate interests, mainly, for security and health and safety purposes.
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If you request further information from us by signing up to receive any of our newsletters or marketing communications (“Marketing Data”). For further details, see section 5 - below.
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Marketing Data is processed for the purposes of sending you the relevant notifications and/or newsletters and/or any marketing communication.
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We will ask you for your name and email address so we can send you this information.
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The legal basis for this processing is consent.
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We may collect certain payment-related information when you make a purchase on our site or through our digital services (“Payment Data”).
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Payment Data is processed to fulfill your transaction, or for purposes of managing your account and collecting payments in connection with our services.
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Information may include credit card, debit card, or bank account information.
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This processing is based on the performance of a contract.
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If you are a proprietor of a business that has credit terms with us, we may also request information to evaluate your credit worthiness (“Credit Data”).
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Credit Data is processed for the purposes of making credit-granting decisions, managing credit that has been granted and managing ongoing credit risk.
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Information may include income, liabilities, credit risk, credit score, amount of credit sought, payment terms, and other information relevant to the granting of credit.
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This processing is based on our legitimate interests in evaluating your request for credit and managing our credit risk.
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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.
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@michelinconnectedfleet.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.
5. 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.
In these situations we will process your personal information to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interests to conduct direct marketing or to the extent you have provided your prior separate consent (please also view "Your rights under data protection legislation" section below to learn how you can control how your personal information is processed by MICHELIN Connected Fleet for marketing purposes);
You can unsubscribe or make direct marketing from us stop at any time by either:
- Clicking on the unsubscribe option at the bottom of each marketing communication we send to you; or
- Contacting us by email or letter using any of the contact details set out in this 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.
6. Sharing your personal information
We may share your personal information with the following:
- Within the Michelin Group: MICHELIN Connected Fleet 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 as the initial processing set out in this policy. In particular your contact data (email address, interests) can be shared within Michelin Group companies in order to know you better and personalise the experience that Michelin companies can bring you and (subject to compliance with local legal requirements) sending you marketing offers and communications related to the newsletters to which you have subscribed.
- Service Providers: MICHELIN Connected Fleet may share your personal information with selected service providers that MICHELIN Connected Fleet 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 ratings and reviews. These service providers are legally required to keep the personal information they may have received confidential and secure and to use your personal information on the basis of our instructions only.
- Third party social networks, advertising networks and websites: MICHELIN Connected Fleet may share personal information so that MICHELIN Connected Fleet can address you on these networks with marketing information. We may transfer data for these purposes to third parties in countries outside the UK and EEA but will only do so if and when the safeguards as provided by GDPR or other applicable local laws have been complied with and provided that you either consented to such transfers or the agreement between you and us provides a basis for such transfers.
- If we are involved in a merger or reorganisation, sell as website or business unit, or if all or a portion of our business, assets or stock are acquired by another company, we may transfer some or all of your personal information to such third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any such transfer of personal information to an unaffiliated third party which will want to continue processing your personal information for the purposes set out above.
We may also share your personal information with third parties:
- Where there is a legal requirement: If we are under a duty to disclose or share your personal information in order to comply with any legal obligation;
- For other legal reasons: in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of MICHELIN Connected Fleet 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.
- On the basis of your consent: Where you accept third party cookies in accordance with our Cookie Policy third parties may collect information about you on our website.
7. International Transfers of personal information
MICHELIN Connected Fleet 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. MICHELIN Connected Fleet 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.
8. 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 information we consider the amount, nature, and sensitivity of your personal information, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve the purposes of the processing through other means, as well as the applicable legal requirements (such as applicable statutes of limitation).
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.
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.
9. Your rights under data protection legislation
You have certain rights regarding your personal information, subject to local data protection laws. These may include the following rights:
- 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;
- to access your personal information held by us (right to access) - 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.;
- to rectify inaccurate personal information and ensure it is complete (right to rectification) - 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.;
- to erase/delete your personal information to the extent permitted by other legal obligations (right to erasure; right to be forgotten) – 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 include, 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 this right does not apply – if you want to know just ask;
- to restrict our processing of your personal information (right to restriction of 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;
- to transfer your personal information to another controller to the extent possible (right to 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;
- to object to any processing of your personal information carried out on the basis of our legitimate interests (right to object). Where we process your personal information for direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
- not to 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;
- 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.
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 the “Contact Us” 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.
10. What can you do if you’re not satisfied 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:
MICHELIN Connected Fleet Data Protection Officer - Djamel Souici
Priory Park
Great North Road, Aberford
Leeds
LS25 3DF
United Kingdom
Email: GDPR@michelinconnectedfleet.com
We will work with you to resolve any issues you may have and aim to answer any question raised by your as soon as possible.
You may also make a complaint to the privacy authority of your jurisdiction.
11. Data Security
We take precautions including organizational, technical, and physical measures, to help safeguard against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the personal information we process or use.
While we follow generally accepted standards to protect personal information, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us via the “Contacting Us” section above.
12. Changes to our Privacy Policy
We will update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements and other factors. If we do, we will update the “effective date” at the bottom of this Privacy Policy. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.
We encourage you to periodically review this Privacy Policy to stay informed about our collection, processing and sharing of your personal information.
[19/12/2023]
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