Last Updated: June 29, 2024
1. Scope of Disclosures
These Additional U.S. Privacy Disclosures (the “U.S. Privacy Disclosures”) supplement the information contained in our Privacy Notice regarding the Michelin Brand websites, products and service offerings, mobile applications, and services that post or link to these U.S. Privacy Disclosures (collectively, “Michelin,” “we,” “us,” or “our”).
These U.S. Privacy Disclosures apply solely to and provide additional information about how we collect, use, disclose and otherwise process personal data, either online or offline, of individual residents of certain states in the U.S. (“data subjects” or “you”) as required under applicable law.
Unless otherwise expressly stated, all terms in these U.S. Privacy Disclosures have the same meaning as defined in our Privacy Notice.
2. Personal Data Disclosures
Personal Data
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. Please review the “Our Collection of Personal Data,” “Our Use of Personal Data,” and “Our Disclosure of Personal Data” sections of our Privacy Notice to learn more. While we do not “sell” personal data in the traditional sense, we do, however, sell or share 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”).
Sensitive Information
The following personal data elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”):
Account name and password;
Driver’s license number;
Credit/debit card number plus expiration data and security code (CVV);
Precise geolocation data.
As described in our Privacy Notice, we use account name and password, as well as payment card information and driver’s license number to provide certain of our products and services. We also use precise geolocation data to provide our Services with geolocation capabilities.
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.
3. 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 with respect to your personal data:
The Right to Know | The right to confirm whether we are processing personal data about you and, under California law only, 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 Request Deletion | The right to request the deletion of personal data that we maintain about you, subject to certain exceptions. |
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. |
4. How to Exercise Your Privacy Rights
Please note that when you submit a request to us to exercise your rights as outlined in the instructions below, your request will be Brand-specific.
To Exercise Your Privacy Rights
Please submit a request by:
Filling out our online form available at: WEBFORM; or
Calling 1-888-971-3804.
We will need to verify your identity and confirm you are a resident of a state that offers the request right(s) under applicable law 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 one of the eligible states.
To Exercise the Right to Opt Out of the Selling or Sharing of Personal Data for Targeted Advertising Purposes
Unless you have exercised your Right to Opt Out, we may “sell” or “share” your personal data to third parties for targeted or cross-context behavioral advertising purposes. 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.
You do not need to create an account with us to exercise your Right to Opt Out. However, we may ask you to provide additional personal data so that we can properly identify you in our dataset and to track compliance with your opt-out request. We will only use personal data provided in an opt out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.
To exercise your Right to Opt Out as it relates to the use of cookies and other tracking technologies for analytics and targeted ads, click on the “Your Privacy Choices” link in the footer of the website for which you wish to opt out of targeted advertising.
Once you make an opt-out request, you may change your mind and opt in, at any time, by returning to the “Your Privacy Choices” link or contacting us at Privacy.AMN@michelin.com.
If you are visiting our site with the Global Privacy Control enabled, any cookies that constitute sales or are used for targeted advertising should already be turned off automatically in our cookie preference manager. Please note this opt-out tool is website-, device-, and browser-specific, so you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting. In addition, you can also opt out of cookie-based sales by businesses that participate in the Digital Advertising Alliance’s CCPA Opt-Out Tool by visiting https://www.privacyrights.info/.
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.
Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by emailing us at Privacy.AMN@michelin.com with the subject line, “Privacy Request Appeal.”
Minors Under Age 16
We do not sell the personal data of consumers we know to be less than 16 years of age. Please contact us at Privacy.AMN@michelin.com to inform us if you, or your minor child, are under the age of 16.
Notice of Financial Incentives
We may choose to provide programs and other offerings intended to provide benefits to eligible participants that may qualify as financial incentives (collectively, “Programs”) under applicable state privacy laws. Through these Programs, we may collect and retain categories of personal data described in the “Our Collection of Personal Data” section of our Privacy Notice, including Identifiers, such as your name, email address, and other contact and account information; and Commercial Information, such as your purchase history and preferences. We collect this information to operate the Programs, including to send you promotions, content, and special offers and the other uses described in the Privacy Notice.
These Programs may include the following:
Discounts, coupons or other access to exclusive content, research, and insights for customers who sign up to receive our marketing communications (e.g., via email or text);
Discounts, coupons, or other benefits in connection with a contest or sweepstakes or similar promotion;
Coupons or other benefits when you refer a friend to use our Services;
Rewards programs for our business customers, where you earn rewards or certain benefits based upon your past purchases or engagements with us; or
Discounts, coupons, cash back, and other special offers for shopping with our partners.
We work with service providers and business partners to offer the various functionalities and benefits of our Programs. The third parties that may receive access to your personal data in connection with any Program are, for example, our Program partners, analytics providers, technical service providers and third-party advertising partners. We may disclose your personal data as set forth in the “Our Disclosure of Personal Data” section of the Privacy Notice.
We have determined that the value of these Programs and other incentives are reasonably related to the value of the personal data we receive and otherwise process in connection with these Programs and offerings, based on our reasonable but sole determination. We estimate the value of the personal data we receive and otherwise process in connection with these Programs and offerings by considering the expense we incur in collecting and processing the personal data, as well as the expenses related to facilitating the Program. In order to communicate and provide services to you through the Programs, we need to use your personal data. Therefore, if you choose to delete your personal data from a Program, we may no longer be able to provide you with services and benefits through the Program.
The material terms applicable to each Program will be explained and described in the relevant Program terms or in the details of the Program offer at the time an eligible individual is offered an opportunity to participate in a Program. Participating in any Program is entirely optional and participants may withdraw from the Program at any time by following the instructions provided in the relevant terms or by contacting us at Privacy.AMN@michelin.com. Participating individuals may also opt out of receiving marketing communications by following the instructions set forth in the “Choices and Control Over Your Information” section of our Privacy Notice above.
Nevada Residents
If you are a resident of the state of Nevada in the United States, you have the right to opt out of the sale of your personal data. Although we do not currently sell personal data of Nevada residents (as defined under Nevada law), you may submit a request to opt out of the sale of your personal data by emailing us at Privacy.AMN@michelin.com.
5. California-Specific Privacy Disclosures
The following disclosures only apply to residents of the State of California:
Personal Data Collection
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 driver’s license information, credit/debit card information, bank account information or other payment information if you engage with one of our Brand ecommerce sites.
Protected Classification Characteristics, such as age.
Commercial Information, such information about products or services purchased or considered, whether you used a particular coupon code or promotion, information about the third-party dealer from whom you purchased a Michelin product, 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, including your IP address and GPS (e.g., latitude and/or longitude), and location information you provide to the Services through our dealer locator tool.
Sensory Information, such as pictures you provide or upload in connection with the Services, and the content and audio recordings of phone calls between you and Michelin and/or you and our service providers, that we record where permitted by law.
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 the “Our Collection of Personal Data” and “Our Use of Personal Data” sections of our Privacy Notice.
Disclosure of Personal Data
As described in the “Our Disclosure of Personal Data” section of our Privacy Notice, we disclose personal data with a variety of third parties for business purposes or we may sell or share your personal data to third parties for targeted advertising purposes, subject to your right to opt out of selling or sharing (see the “Your Privacy Rights” section above).
In the previous 12 months, we have sold or shared for targeted advertising purposes all of the categories of personal data we collect, explained above, to third parties.
California’s “Shine the Light” Law
At the time of this writing, we do not provide your personal data to third parties for their direct marketing purposes, as described in California’s “Shine the Light” law (Civil Code Section §1798.83). To opt out of having your personal data disclosed to third parties for their direct marketing purposes in the future, please email us at Privacy.AMN@michelin.com with the subject line, “Shine the Light Request.” Please note that to opt out of all disclosures to third parties for direct marketing purposes, you must provide your personal data to be added to our suppression list.
6. 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 updating the “Last Updated” date above or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
7. 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 Privacy.AMN@michelin.com.
Alternatively, inquiries may be addressed to:
North American Privacy Officer
Michelin North America, Inc.
One Parkway South
Greenville, SC 29615