We would like to thank you for your interest in Truckfly by Michelin (the “Application”) and its services.

This personal data protection policy (the “Policy”) describes the policy of the Manufacture Française des Pneumatiques Michelin (hereafter referred to as “we” or “Michelin”) concerning the collection, use and disclosure of information concerning you (“Personal Data”), in the framework of our Truckfly service, including our website truckfly.com and the Truckfly mobile app (collectively, the “Service”), and the use of cookies.

The Policy is designed to allow you to make decisions in full knowledge of how the Services are used. We kindly ask you to read the Policy before using our Services and every time it is updated.

1. WHO ARE WE?

2. THE PERSONAL DATA WE COLLECT

3. WHY AND HOW WE USE YOUR PERSONAL DATA

4. COMMUNICATION AND TRANSFER OF YOUR PERSONAL DATA

5. CONTROL OF YOUR PERSONAL DATA

6. RETENTION OF YOUR PERSONAL DATA

7. MINORS

8. SAFETY

9. YOUR RIGHTS

10. COOKIES

11. CONTACT

12. MODIFICATION OF THIS CONFIDENTIALITY POLICY

1. Who are we?

The Service is offered by Manufacture Française des Pneumatiques Michelin, a company with capital of €504,000,004, listed on the Clermont-Ferrand company register under number 855, 00 507, with head offices located at Place des Carmes Déchaux, 63040 Clermont-Ferrand Cedex 9. Acting as the controller of your Personal Data collected as part of using the Service.

2. The Personal Data we collect

In order for you to use this Service, we collect:

A - Account data: If you create an account on the Application, we may store and use your full name, age, email and phone number. If you complete your profile, we may store and use your city, type of transportation, brand, model and year of your truck.

Your first name and the initial of your last name that you submit when you register as well as the photos and information of your truck that you can enter in your profile will be made public as part of your account profile.
If you believe that an unauthorized account has been created that represents you or looks like you, you can request that it be deleted by contacting us.

B - Your reviews, comments, favourites, likes, modified and added locations, account profile.

C - The list of your contacts: You can invite your friends to join the Service by giving us access to the contacts in your mobile phone or from third-party sites, to select the friends you wish to invite.

D - Marketing data: If you wish to obtain additional information by signing up to our newsletters or other communications, marketing data will be used to send you relevant communication and/or newsletters in line with your needs. We ask for your name, email and/or telephone number in order to send you the requested communication. We will send you communication only if you have given us your consent, or unless you oppose it, when permitted by law. You can manage your communication preferences in the settings of the Application. We can follow your actions in response to messages that you receive from Michelin or via the Service, in particular when you delete, open or transfer them.

Please note however that you cannot refuse to receive certain administrative or legal notifications from Michelin.

E - Company data: If you are the representative of a company referenced on the Application, we may contact you, including by telephone or email, using the contact information you provide us that is presumed to be professional, that you make available to the public or that we have recorded for your establishment.

F - Contact details: If you decide to contact us, we may save the data you include in your message.

G - Activity and geolocation: We may store data relating to your use of the Service, such as your searches, the pages you visit, the date and time of the visit and the companies you contact using our Application. We may also store data about your use of the Service that your computer or mobile device provides to us, such as your browser type, computer or mobile device type, browser language, IP address, mobile operator, unique device identifier, geographic location (including geolocation, beacon location and GPS location) and requested URLs and referring URLs. You may be able to opt-out of our use of certain location data in the privacy section of the Application or through your mobile device or browser settings, for example by disabling 'Location Services' for the Application in your device's privacy settings.
Some of this information is required to identify you when setting up your account. If you do not provide all the required information, your user account cannot be created. Required information is marked as such in the forms.

3. Why and how we use your Personal Data?

We use your Personal Data for specific purposes, each based on a legal provision, as described below:

Purpose	Legal basis
Deliver the Service and ensure it operates correctly,	The Service is delivered in line with our General terms and conditions of use that you agree to when you sign up to the Service. We therefore need to process your Personal Data to fulfil our obligations in the framework of this binding relationship. Certain features of the Service use geo-location which requires your consent.
Improve the quality of the Service, market it and develop it	We have a legitimate interest in providing you with the best Service possible, and developing our activities.
Monitor the use of the Service and customise your experience	We have a legitimate interest in providing you with the best Service possible, and fulfilling your needs and expectations.
Conduct a survey or poll	We have a legitimate interest in monitoring and improving the products and services provided to customers and users by Michelin or its partners
Fulfil your needs and take appropriate action	We have a legitimate interest in fulfilling your needs and expectations.
Communicate with you to drive forward marketing operations	The use of your Personal Data for marketing purposes is based on our legitimate interest in developing our customer relations with you. We will send you communication only if you have given us your consent, or unless you oppose it, when permitted by law.
Provide you with customer support	We have a legitimate interest in providing you with support at your request.
Provide and improve the security of the Service, in particular by backing up our systems for restoration after a failure	We have a legitimate interest in protecting the security of our goods and Services
Protect our rights and our goods, including those belonging to other users of the Service	We have a legitimate interest in protecting the rights and security of our goods and Services, as well as those of our users.
Comply with our legal obligations, and any legal decisions or procedures, as well as the requirements set by regulatory authorities	We may use your Personal Data for business transactions, to assert our legal rights, or protect third-parties, based on our legitimate interest or that of the third party. As for other purposes described in this section, we are obliged to use your Personal Data to comply with the relevant legal requirements.

4. Communication and transferral of your Personal Data

In the framework of this Service, we may share your Personal Data with the following categories of third parties:

• Parties to whom we outsource certain services, notably including IT service providers, publishers, and support providers,

• Service providers to help us analyse client data, e.g. Google Analytics and Flurry,

• Private message providers to help us with email campaigns, in particular Sendgrid ;

• With your consent when required, we may share your information with business partners or other companies, in which case we require them to comply with this Policy,

• Aggregated information: We may give third parties access to user information in aggregated form, in particular with advertisers and content distributors. For instance, we may reveal the number of users exposed to advertising or who clicked on ads,

• If you report or send complaints to Michelin about the content of the Service, we may share the main message of your complaint with the contributor of the content to allow them to respond,

• We will also respond to requests for information if legally bound, or if such disclosure is required to protect our rights and/or comply with legal procedures or verdicts, requests from the regulator or any other legal procedure involving us.

• Links: The Service may contain links to the services of non-partner third parties. Unless otherwise stated in this Policy, we will not share your personal information with them, and we are not liable for their confidentiality compliance. We recommend that you read the confidentiality policy on websites of all other services concerned or those applicable to them. Facebook and Twitter: If you link your Application account to a third party service such as Facebook or Twitter, we may receive information concerning you from these third party services. We may use this information to help you create your account on the Application and sign in to share your public content with your friends and subscribers. You can manage how you link your account to third party services. Please note that if you interact with Facebook, Twitter or other third-party icons via the Service, including ‘like’ and ‘share’ buttons, or other similar features, these companies may collect information about you, in particular the IP address used by your device. Your interactions with these third parties and with others are governed by their confidentiality policies.

• Data transfer: if your Personal Data is transferred outside the European Economic Area (EEA) to service providers, we will ensure that your Personal Data is protected by the same level that is provided if it remains within the EEA, for instance by signing data transfer deals based on standard contract clauses approved by the European Commission and updated or revised, or via certification programs - for transfers to the USA or other transfer systems such as adequacy decisions, binding corporate rules, or contracts approved by the EU Data Protection Authorities. You have the right to obtain information about the system used to transfer your personal data outside the EEA and the country to which it is transferred by contacting truck[email protected].
For your information, your Personal Data (name, email address, telephone number) is currently only transferred outside the EEA to our supplier Sendgrid for the purpose of managing email campaigns and to our supplier Google group, Google LLC, Google Ireland Limited, Google Asia Pacific Pte. Ltd. to manage the telephone number authentication service.

• Personal Data is an asset covered by transfer operations in the event of a merger, acquisition, partial transfer of assets, or other changes of control concerning the Application. The transfer, and the alternatives offered to the User concerning the fate of Personal Data, will be notified as soon as possible in a message posted on the website and/or by email if the user’s email address has been provided.

5. Control of your Personal Data

Other users may be able to identify you, or recognise you via your user account if you include personal information in the content you publish. You can reduce the risk of being personally identified by using the Service with an alias, although this may reduce the credibility of your contributions to the Service.

6. Retention of your Personal Data

You can close your account at any time by sending your request by email to [email protected].

We will cease to display your published articles and/or dissociate them from your user account.

We may retain your Personal Data in the following conditions:

• We always keep your Personal Data for the time strictly needed to accomplish the task for which it was collected, in other words, for as long as you use the Service,

• We will keep your Personal Data for marketing purposes for three years after your last interaction with us unless you oppose this when you receive one of our messages,

• The IP addresses collected for security purposes will be kept for no longer than 10 days,

• The sign-in logs collected will be kept if you consent, using cookies and other trackers used for the Service, for no longer than thirteen (13) months, in compliance with the applicable laws and regulations. For further details, please refer to the Cookies section below.

• We may be required to keep your Personal Data on archive beyond the period given below in compliance with our legal obligations or if required given the applicable prescription to exercise our rights

• As soon as your Personal Data is no longer needed for the intended purpose or for archiving to fulfil our legal obligations, we will ensure that it is completely destroyed or anonymised.

If you allow us access to your contacts, we may send this information to the Application for the period needed to deal with your invitations. Please note that companies cannot delete data for points of interest, reviews, or comments concerning points of interest when closing their accounts, unless legal or regulatory provisions state otherwise.

7. Minors

The Service is designed for the general public, but is not intended for users under 16. We do not voluntarily collect personal information concerning children under 16. If you discover that a child under 16 has provided us personal information without parental approval, we will take the necessary measures to delete that information and will close the child’s account.

8. Security

We fulfil the standards generally applied by the sector to protect personal information that we receive, both when it is sent and after we have received it. Nonetheless, no methods used to transfer data via the internet or mobile device, nor any electronic storage methods, are 100% secure. As such, although we strive to use commercially acceptable methods to protect personal data, we cannot guarantee absolute security.

9. Your rights

In compliance with the legal provisions, you are entitled to the following rights concerning your Personal Data:

• The right to access your Personal Data, in particular the right to obtain a copy of it as well as information on how Personal Data is processed and the legal basis used,

• The right to rectify any incorrect Personal Data (including the right to complete any incomplete Personal Data),

• The right to delete your Personal Data (this can only be applied once it is no longer needed to complete the task for which it was collected or processed),

• The right to restrict the processing of your Personal Data when:

      • You disagree with the accuracy of your Personal Data that we are processing,

      • The processing is illegal but you oppose the deletion of your Personal Data,

      • We no longer need your Personal Data but it is still needed for legal procedures,

• The right to transfer your Personal Data in a form that can be read by a machine for a third party (or by yourself) if our processing is based on your consent or on the execution of a contract that was signed with you,

• The right to give general or specific instructions on the method of processing and using your Personal Data after your death,

• The right to oppose all telephone contact for marketing purposes, at any time, by signing up to the free website www.bloctel.gouv.fr,

• The right to withdraw your consent to processing your Personal Data at any time (if this processing depends on your consent) without affecting the lawfulness of the processing based on the consent given before it is withdrawn,

• In addition to the above-mentioned rights, you have the right to oppose all processing of your Personal Data justified by Michelin’s legitimate interest, including profiling (contrary to a justification based on your consent, or to fulfil a contract with you). You are also free to oppose the use of your Personal Data for commercial purposes, including for profiling.

• Obtain or consult a copy of appropriate measures taken to transfer your Personal Data to another country or international organisation.

• You have the right to make a complaint with your local data protection authority. For France : CNIL, 3 Place de Fontenoy, 75007 Paris, France.

To exercise these rights, please contact us using the contact information provided below under the 'Contact' section or the 'Exercise Your Rights' section of the Application and Website. Please note that we can ask you for proof of ID and reserve the right to invoice you for the cost involved when legally authorised if your request is manifestly unfounded or excessive. We will strive to respond to your request within the given timeframe.

10. Cookies

A cookie is a small file that can be placed on the hard drive of your device or on the server of a website. We use cookies to obtain certain information automatically collected as described above. You are not required to accept cookies and can choose which ones you accept by changing the settings of your browser to refuse them. For more information on cookies, including how to configure your web browser to refuse or better control the installation of cookies on your device, please visit Cookies policy.

Cookie management and deletion

In order to control the use of cookies on our website, when you access our website you are asked to set up various cookies which you have authorised to install. Please visit this link for more information. If you refuse cookies, we will not put any other cookies on your device except the functional cookies presented above (in particular a cookie to memorise the fact that you do not want cookies installed when you visit our website).

11. Contact

If you have any questions about this Policy, or if you wish to exercise any of your rights, please send us an email to [email protected]

12. Modifications to this Policy

This Policy is subject to updates to incorporate any changes to laws and/or our Personal Data protection practices.

Date of the last update: 26/02/2021