Last Updated: November 5, 2024
This Privacy Notice explains how we collect, use, disclose, and otherwise process your personal data in connection with our Services.
Who We Are: Michelin North America, Inc. (MNAI), Michelin North America (Canada) Inc. (MNA(C)I), Michelin Retread Technologies, Inc. (Michelin Retread Technologies), Michelin Retread Technologies (Canada) Inc., Oliver Rubber Company, LLC, and Oliver Rubber Canada Limited (collectively, “Michelin,” “we,” “us,” or “our”) with operations throughout the United States and Canada.
Our Services: When we use the term “Services,” we are referring only to the products and services that we offer through our brands, including without limitation, Michelin, BFGoodrich, Uniroyal, Michelin Retread Technologies, Oliver, and Tweel, that post or link to this Privacy Notice (the “Brands”) such as products, websites, digital services, mobile applications, and services.
This Privacy Notice does not cover or address, for example:
- Any of Michelin’s other product or service offerings, including other websites and mobile applications that do not post or link to this Privacy Notice. To learn more about Michelin’s personal data practices relating to these other products or service offerings, please review their respective privacy notices and policies.
- Personal data and privacy practices relating to job applicants, employees, or other personnel.
- Privacy practices of independent third-party retailers that sell Michelin products.
Your use of the Services is subject to this Privacy Notice and the applicable Terms of Use:
If you do not agree with any term in this Privacy Notice, please do not use the Services or submit any personal data. Please read the following Notice carefully to understand our views and practices regarding your personal data and how we will treat it.
Customer Data
Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (or the why and the how) of processing personal data. A “processor,” which is sometimes referred to as a “service provider,” processes personal data on behalf of a controller subject to contractual restrictions.
As part of our business relationship with our customers, we are often asked to receive, gather, store, analyze, or otherwise process information, which may include personal data, on behalf of our customers. We refer to this type of information and personal data as “customer data.” When we process customer data, we generally act as a processor. This means we process customer data on behalf of our customers, subject to restrictions set forth in our contracts with them.
This Privacy Notice does not cover or address how we or our customers process customer data in connection with our role as our customers’ processor. Instead, this Privacy Notice only covers our processing of personal data in our capacity as a controller. In addition, we are generally not permitted to respond to individual requests relating to customer data. As a result, we recommend referring to the privacy notice of the business or government organization with which you have a relationship for information on how they engage processors, like us, to process customer data on their behalf.
Region-Specific Disclosures
Depending on your country, province or state of residence certain rights may apply to you. Please refer below for disclosures that may be applicable to you:
What is Personal Data?
When we use the term “personal data” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a person or household. It does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to a person.
1. Our Collection of Personal Data
We collect personal data about you in a variety of ways. Sometimes we collect personal data automatically when you interact with the Services, and sometimes we collect the personal data directly from you. At times, we may collect personal data about you from other sources and third parties, even before our first direct interaction. We may link or combine your activities and information collected from you on our websites with information we have collected from you offline (e.g., at an event), information we receive from third parties, as well as information we collect automatically through tracking technologies.
Personal Data You Provide
We may collect the following personal data from you while providing our Services:
- Contact Information, including your name, email address, telephone number, address and zip/postal code, preferred language, and customer profile when you purchase a product from a Brand e-commerce website or register for the Services, submit information through our warranty or rebate registration process, take advantage of or participate in an offer or promotional activity (e.g., sweepstakes or contest), sign up for our newsletters, request further information from us, respond to a survey or questionnaire, or otherwise communicate with us or interact with the Services.
- Payment and Transaction Information, including information collected on a Brand e-commerce website or saved in a Michelin account profile such as products purchased, the third-party dealer from whom you purchased a Michelin product, date and time of your transaction, amount purchased, order details, whether you used a particular coupon or promotion, and payment information when you make a purchase or transaction from the e-commerce website. Payments may be processed by third-party payment processors. Please refer to the applicable processor’s terms and privacy policy for more information about how payment information is processed and stored.
- Inquiry and Communication Information, such as the content of your email, live or automated chat conversation or contact form submission on our websites, and, where applicable, the content of calls with us when you contact us. We may also collect any other communications between you and Michelin and any other information and content you provide to Michelin.
- Sensory Information, including pictures you provide or upload in connection with the Services, and the content and audio recordings of phone calls between you and Michelin and you and our service providers, including our third-party call center operations vendors, that we record where permitted by law.
- Demographic Information, including age.
- Account Information, including your username and password.
- Vehicle and Driver’s License Information, including driver’s license information, VIN number, Department of Transportation (DOT) code, 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.
- Professional/Employment Information, including your job title, department, employer or business, type of industry, and trade or professional association membership information. If you participate in our Two-Wheel Dealer Engagement Program, we may also collect first and last name, profile photo, and rewards points.
- Location Information, including information about your physical location that you upload to the Services, such as when you use our dealer locator tool to identify nearby dealers of Michelin products or interact with our emergency roadside services. We may also collect precise geolocation if you grant us permission to access such data through your device settings (for example, if you use the BFGoodrich OnTrail mobile app).
- Personal Life Information, such as life habits (hobbies) and family situation.
- Economical and Financial Information, revenue, socio-demographic information, and socioeconomic category.
Personal Data Automatically Collected
As is true of most digital platforms, we may collect certain personal data automatically when you visit our online services, including:
- Log File Data, including your internet protocol (IP) address, operating system, browser type, browser id, date/time of visit, and pages visited.
- Analytics Data, including the electronic path you take to the Services, through the Services and when exiting the Services, as well as your usage and activity on the Services, such as the links and object you view, click, or otherwise interact with (also known as “Clickstream Data”).
- Location Data, including your general geographic location based on your IP address or more precise location when accessing our online services through a mobile device. We may also use the Google Maps Application Programming Interface to gather information about your location. Google uses various technologies to determine your location, including your IP address, GPS, and other sensors that may, for example, provide Google with information on nearby devices, Wi-Fi access points, and cell towers (to learn more, please see Google Maps’ privacy policy at: https://policies.google.com/privacy). We may also collect precise geolocation from our mobile apps if you grant us permission to do so. To change your device settings regarding our collection of precise geolocation, see the “Choices and Control Over Your Information” section below.
- Information You May Post/Submit to our Services. We may collect information about how you use and interact with our Services, including any information and content you post to the Services. If you share photos and video from a mobile device, we will access your device camera roll and camera with your permission as needed to post your content. If you need to update your permissions, you can do so in the “Settings” app of your device.
- Information About How You Use the Services, for example, the pages you visit, the links you click, the ads you view and click on, videos you watch, purchase information and your checkout process, your location when you access or interact with our Services, and other similar actions. We may also use third-party tools to collect information you provide to us or information about how you use the Services and may record your mouse movements, scrolling, clicks and keystroke activity on the Services and other browsing, search or purchasing behavior. These tools may also record information you enter when you interact with our Services or engage in chat features through our Services.
We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, mobile SDKs, location-identifying technologies, and similar technology, and we may use third-party partners or technologies to collect this information. All of the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Services, and to improve the effectiveness of our Services, offers, advertising, communications features such as live and automated chat, and customer service functionality.
For information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and the choices you have in relation to its collection, please visit the Cookie Notice of the relevant Michelin brand website by clicking on “Your Privacy Choices” in the footer of the applicable website.
Personal Data Provided by Other Sources
We also may obtain your personal data from other sources which we often combine with personal data we collect either automatically or directly from you.
We may receive the same categories of personal data as described above from the following sources and third parties:
- Our Brands: We may receive information about you from our other Brands and affiliates, so that information you provide to one Brand or affiliate may be used by us to provide you Services, communicate with you or provide you advertisements or other personalized content.
- Service Providers: Our service providers that perform services on our behalf, such as our call center operations vendors, identity verification providers, payment processors on a Brand e‑commerce website, third party dealers that deliver products and services on our behalf, and analytics providers. For example, we may receive personal data from our service providers that conduct call center support, marketing, or analytics activities.
- Business / Promotional Partners: Our business and promotional partners whom we partner with to provide our contests, sweepstakes or other joint promotional activities or co-branded services may collect personal data in connection with these activities and may share some or all of the information with us.
- Social Networks: When you interact with the Services through various social media networks, such as when you “Like” us on Facebook or when you follow us or share our content on Facebook, Pinterest, Twitter, Instagram, YouTube, LinkedIn, or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third party websites and social media networks and services before linking or connecting them to the Services.
- Other Third Parties and Publicly Available Sources: From time to time, we may receive information about you from third parties. For example, we may obtain information from our marketing partners or from third parties to enhance or supplement our existing user information. Where permitted by applicable law, we may also collect information about you that is publicly available, including contact information, employment-related information, and product interest information. We may combine this information with the information we collect from you directly.
Business Representatives Data Collection Practices
We also may collect professional personal data about representatives of third-party businesses, including representatives of our business and enterprise customers and business partners, in connection with our Services and the operation of our business, which may include:
- Contact Information: Including full name, email address, mailing address, and telephone number.
- Professional Information: Including job title, job function, company name and characteristics, professional background, and nature of the relationship with us.
- Tax and Payment Information: Including a personal tax identification number, Social Security Number and birthdate, bank account information, and payment information where the individual is a representative of a sole proprietor or similar legal structure that uses personal tax and account information in lieu of separate business information.
- Contract Information: Including any information relating to our contractual relationship.
- Inquiry Information: Including the contents of emails, texts, and other communications and, where permitted by law, recordings of calls with us.
- Feedback Information: Including information provided in response to surveys we may conduct with customers or business partners, or unsolicited feedback received regarding our services and business.
If you engage in our services or interact with us through your employer, company, or organization, we may receive the above information from the company.
2. Our Use of Personal Data
We may collect, use, and disclose your personal data for purposes identified at the time of collection, or as otherwise permitted or required by law, including the following purposes:
- To fulfill or meet the reason the information was provided, such as to process your requests or payment on a Brand e-commerce website in connection with your transactions, to respond to inquiries, and/ or to process your warranty or rebate claims and registration for the Services, including verifying your information to ensure its accuracy and validity.
- To personalize your experience (e.g., to locate a nearby dealer of Michelin products) and customize content on the Services relevant to your interests, including but not limited to targeted offers and ads through our websites, email, social media channels, third-party sites, or on other devices you may use.
- To communicate with you, including via email, text message, chatbot, push notification and/or telephone calls.
- To operate, maintain, and provide the features and functionality of the Services.
- To complete the performance of the Services pursuant to an agreement between you and us.
- To send you important information regarding the Services, such as certain changes to our terms, conditions, policies, and/or other administrative information. Because this information may be material to your use of the Services, you may not opt out of receiving such communications.
- To send you certain product recall notifications or information.
- To market our products and services to you and to inform you of products, programs, services, and promotions that we believe may be of interest to you, including, without limitation, adding you to our email/mailing lists and permitting you to participate in sweepstakes, contests, rebates and similar promotions (collectively, “Promotions”) or following up with you if you are the winner of a Promotion.
- To evaluate your eligibility for certain types of Promotions, offers, products or services that may be of interest to you.
- To help maintain the safety, security, and integrity of the Services, technology assets, and business.
- For our internal business purposes, such as data analysis, customer research, audits, fraud prevention, developing new products and/or features, evaluating, enhancing the Services, improving the Services, and identifying usage trends, and determining the effectiveness of our promotional campaigns, including to inform our machine learning for purposes such as user engagement.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations and enforce our corporate reporting obligations and the applicable Terms of Use, or to comply with applicable laws.
- For purposes disclosed at the time you provide your personal data or as otherwise set forth in this Privacy Notice.
We will only keep your personal data for as long as necessary to fulfill the purpose for which it was collected or as otherwise required or permitted by applicable law.
We may also use aggregate personal data in a manner such that the end product does not uniquely identify you or any other user of the Services, for example to compile statistics about the Services based on responses to our product surveys or questionnaires.
We may provide additional privacy disclosures where the scope of the inquiry/request and/or personal data we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we collect, use, and disclose the information you provide at that time.
Segmentation and Targeting
As part of our services, Michelin 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 Michelin 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.).
Michelin 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.
3. Our Disclosure of Personal Data
We may disclose your personal data for purposes and uses that are consistent with this Privacy Notice in the following ways:
- Within Michelin: We may disclose personal data between and among Michelin and its current and future parents, affiliates, subsidiaries, our Brands, and other companies under common control or ownership.
- International Transfers of Personal Data: Michelin is an international group with activities around the world. We may transfer your personal data as described in this Privacy Notice to a country other than the country where we originally collected it. Those countries may not have the same personal data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Notice and take steps, where necessary, to ensure appropriate safeguards are in place.
- Business / Promotional Partners: We may share limited information with third parties with whom we partner to provide contests and sweepstakes, or other joint promotional activities or co-branded services.
- Online Advertising Partners: We may also share personal data with advertising networks or permit these partners to collect information from you directly on our websites to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms. For more information, including how to opt out of interest-based advertising, please read the applicable website Cookie Notice accessible via the “Your Privacy Choices” in the footer of the applicable website.
- Service Providers: We may disclose personal data with third-party vendors, third‑party dealers, consultants, and other service providers whom we engage to perform functions or services on our behalf and under our instructions in connection with the purposes and uses described in this Privacy Notice. For example, this may include vendors and providers who provide text messaging services, chatbot functionality, tax and accounting services, auditing and compliance, fraud prevention, infrastructure provisioning, analytics services, IT services, product fulfillment, and web hosting.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal data to a third party during negotiation of, in connection with, or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy, or receivership, in compliance with applicable law.
- Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect the rights and property of Michelin, our agents, customers, and others, including to enforce our agreements, policies, and the applicable Terms of Use;
- to detect, suppress, or prevent fraud;
- to reduce credit risk and collect debts owed to us;
- to protect the health and safety of us, our customers, or any person; or
- as otherwise required by applicable law.
- With Your Consent or At Your Direction: We may disclose personal data about you to certain other third parties with your consent or at your direction.
4. Children's Personal Data
Our websites and online Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 14. If you are under the age of 14, please do not use our websites or online Services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 14 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we have collected has been provided by a child under the age of 14, we will promptly delete that personal data.
5. Third-Party Websites
Our websites and online Services may include links to third-party websites, plugins, and applications. 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 data practices of third-party websites and online services or the practices of other third parties. To learn about the personal data practices of third parties, please visit their respective privacy notices.
6. Choices and Control Over Your Information
Modifying and deleting your information: As applicable, if you have an account with us, you may update your account information and adjust your account settings by logging into your account. Please note that changes to your settings may require some time to take effect.
Access to device information: You may control the Services’ access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the Services, including our mobile apps, to access your network devices and geolocation.
How to control your email preferences: You can stop receiving promotional email communications from us at any time by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the service, and technical and security notices).
SMS text messages and telephone calls: We may use personal data we collect to communicate with individuals via text message and telephone calls, including (with your consent) to market to you or offer you information and updates on products or services we think you may be interested in. You can unsubscribe from marketing calls or text messages at any time by replying STOP or clicking the unsubscribe link (where available) in one of our messages. Sharing excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties. For more information, please see our Terms of Use (available at the top of this Privacy Notice).
Cookies and online advertising and tracking: Please refer to the applicable website Cookie Notice to learn more about how we work with third party partners to collect data through tracking technologies for various purposes, including analytics, advertising, and to understand your choices.
7. Retention of Personal Data
We retain personal data only for as long as is reasonably necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator, or other government authority.
To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.
Therefore, we retain personal data for as long as the individual continues to use our services for the purposes explained in the “Our Use of Personal Data” section in our Privacy Notice. When an individual discontinues the use of our services, we will retain their personal data for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices they have made, such as to receive marketing communications. In particular, we will retain call recordings, the personal data supplied when joining our services, including complaints, claims (for insurance products) and any other personal data supplied during the duration of an individual’s contract with us for the services until the statutory limitation periods have expired, when this is necessary for the establishment, exercise, or defense of legal claims.
Once retention of the personal data is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal data and isolate it from further processing until deletion or deidentification is possible.
8. Updates to This Privacy Notice
We may make updates to our Privacy Notice from time to time. Any changes we make to this Privacy Notice in the future will be posted on this page. All changes shall be effective from the date of publication unless otherwise provided.
9. Accountability and Contact
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to Privacy.AMN@michelin.com
Alternatively, inquiries may be addressed to:
North America Privacy Officer
Michelin North America, Inc.
One Parkway South
Greenville, SC 29615