Privacy Statement
EFFECTIVE DATE: January 30, 2023
This privacy policy (“Policy”) describes how Michelin Mobility Intelligence (“we” or “us”) collects, uses, discloses and otherwise processes the personal information described in this Policy, as well as the rights and choices individuals have regarding such personal information. This Policy applies to the extent we process personal information on our own behalf, as a controller or business.
For information about the privacy choices you have regarding your personal information, review Section 7, “Your Privacy Choices,” below. If you are a resident of California, please also refer to Section 12, “Additional Privacy Information for California Residents,” below, for information about the categories of personal information we collect and your rights under California privacy laws.
Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms and Conditions, including their applicable limitations on damages and the resolution of disputes.
1. Scope
Except as otherwise noted below, this Policy applies to the personal information that Michelin Mobility Intelligence processes as a controller or business related to:
- users of our websites where this Policy is posted, including roadbotics.com, our mobile applications, and the services we provide through these (collectively, the “Services”).
- individuals who are subscribed to receive news, information and marketing communications from us;
- individuals who communicate with us or otherwise engage with us related to our Services.
Not In Scope. This Policy does not apply to the personal information that we collect and process about Michelin Mobility Intelligence employees and personnel or job applicants and candidates. In addition, this Policy does not apply to the extent we process personal information, as a processor or service provider, on behalf of our business clients (“Client Content”). Our processing of Client Content is subject to the terms of our contracts with each business client, who is the controller and business for the Client Content that we
process on their behalf.
2. Personal Information We Collect
As further described below, we collect personal information directly from individuals and automatically, related to the use of our Services or other interactions with us.
Personal Information Collected Directly. The personal information we collect from you depends upon how you use our Services or otherwise interact or engage with us, but generally includes:
- Registration and profile information. When you register for an account with us, we collect certain personal information from you, such as your name and email address.
- Communications and interactions. When you email, call, or otherwise communicate with us and with members of our team, we collect and maintain a record of your contact details, communications and our responses. We also maintain records of information you provide to us related to any customer support requests.
Personal Information Collected Automatically. We automatically collect personal information related to your use of our Services and interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the Services. Such information includes:
- Device and browsing information. We use cookies, log files, pixel tags and other tracking technologies to automatically collect information when users access or use our Services, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. For more information, see Section 5, “Cookies and Tracking,” below.
- Activities and usage. We also collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, and time spent within the Services.
- Location information. We may collect or derive location information about you, such as through your IP address. Further, with your permission, we may collect geolocation information from your device. You may turn off location data sharing through your device settings.
3. Purposes of Collection and Processing
Generally, we collect, use and otherwise process the personal information we collect for the following purposes:
- Services and support. To provide and operate our Services, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your requests, communicate with you, and for similar service and support purposes.
- Analytics and improvement. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations, to develop services and features, and for internal quality control and training purposes.
- Security and protection of rights. To protect the Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to protect our rights, those of stakeholders or any third party; to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms & Conditions or this Policy.
- Legal proceedings and obligations. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings.
- General business and operational support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.
4. Disclosures of Personal Information
Generally, we disclose the personal information we collect in order to provide our Services to you, respond to and fulfill your orders and requests, as otherwise directed or consented to by you, and for the purposes otherwise described in this Policy, including:
- Services and support. To provide and operate our Services, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for similar service and support purposes.
- Analytics and improvement. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations, to develop services and features, and for internal quality control and training purposes.
- Marketing, advertising, and campaign management. We may disclose certain information that includes personal information to third-party ad network providers and/or traffic measurement services, which may use this data to improve and measure the effectiveness of our ads. For more information, see Section VI, “Advertising and Targeting,” below.
- In support of business transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or as part of a financing, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. We may also share certain personal information as necessary prior to the completion of such a transfer, such as to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for the transfer.
- Compliance, governance, and legal requirements. To comply with legal and compliance obligations, to respond to legal process and related to legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions. In addition, we may disclose the names of sweepstakes and contests winners, in accordance with applicable law.
- Security and protection of rights. To protect the Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; to protect our rights, those of stakeholders and any third party; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms and Conditions or this Policy.
We disclose and make available personal information, for the purposes described above, to third parties, which generally includes:
- Vendors and service providers. We may disclose personal information we collect to our service providers, processors and others who perform functions on our behalf. These may include, for example, analytics providers, consultants, auditors, and legal counsel.
- Our affiliates. We may disclose personal information we collect to our affiliates.
- Third party analytics providers. We may disclose or make available personal information to third party analytics providers and advertising networks in support of our marketing, advertising and campaign management.
- Partners. We may disclose personal information to third parties in support of a business transfer. This may include potential and actual acquirers, business partners, or financiers and their employees, representatives, and counsel.
- Others as required by applicable law. We may also disclose personal information to third parties to the extent required by applicable law and legal or contractual obligations. This may include regulators, government entities, and law enforcement as required by law or legal process.
4. Disclosures of Personal Information
Generally, we disclose the personal information we collect in order to provide our Services to you, respond to and fulfill your orders and requests, as otherwise directed or consented to by you, and for the purposes otherwise described in this Policy, including:
- Services and support. To provide and operate our Services, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for similar service and support purposes.
- Analytics and improvement. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations, to develop services and features, and for internal quality control and training purposes.
- Marketing, advertising, and campaign management. We may disclose certain information that includes personal information to third-party ad network providers and/or traffic measurement services, which may use this data to improve and measure the effectiveness of our ads. For more information, see Section VI, “Advertising and Targeting,” below.
- In support of business transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or as part of a financing, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. We may also share certain personal information as necessary prior to the completion of such a transfer, such as to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for the transfer.
- Compliance, governance, and legal requirements. To comply with legal and compliance obligations, to respond to legal process and related to legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions. In addition, we may disclose the names of sweepstakes and contests winners, in accordance with applicable law.
- Security and protection of rights. To protect the Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; to protect our rights, those of stakeholders and any third party; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms and Conditions or this Policy.
We disclose and make available personal information, for the purposes described above, to third parties, which generally includes:
- Vendors and service providers. We may disclose personal information we collect to our service providers, processors and others who perform functions on our behalf. These may include, for example, analytics providers, consultants, auditors, and legal counsel.
- Our affiliates. We may disclose personal information we collect to our affiliates.
- Third party analytics providers. We may disclose or make available personal information to third party analytics providers and advertising networks in support of our marketing, advertising and campaign management.
- Partners. We may disclose personal information to third parties in support of a business transfer. This may include potential and actual acquirers, business partners, or financiers and their employees, representatives, and counsel.
- Others as required by applicable law. We may also disclose personal information to third parties to the extent required by applicable law and legal or contractual obligations. This may include regulators, government entities, and law enforcement as required by law or legal process.
5. Cookies and Tracking
We and our third-party service providers use cookies, pixels, java script, log files, and other mechanisms to automatically collect information browsing, activity, device and similar information within our Services. We use this information to, for example, analyze and understand how users access, use and interact with others through our Services, as well to identify and resolve bugs and errors in our Services and to assess, secure, protect, optimize and improve the performance of our Services. You have certain choices about our use of cookies within the Services, as described in this section. For more information on our use of cookies, please review our cookie statement.
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within the Services.
Pixel Tags. Pixel tags (sometimes called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, help us manage content and compile usage statistics.
Third-Party Analytics and Tools. We use third party tools, such as Google Analytics, to evaluate usage of our Services and to help us improve performance and user experiences. These third-party tools may use cookies and other tracking technologies, such as pixel tags, to perform their services. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Browser Solutions for Disabling Cookies. If you wish to prevent cookies from tracking your activity on our website, you can set your browser to block certain cookies or notify you when a cookie is set. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to access the Site, but some features may not function.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
6. Advertising and Targeting
We work with third parties, such as ad analytics and measurement services and others (“third-party ad companies”) to manage our advertising on third-party sites, mobile apps and online services. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect activity information on third-party sites and services, as well as IP address, location information, device ID, cookie and advertising IDs, and other identifiers. We and these third-party ad companies use this information to provide you more relevant ads on third-party sites and apps, and to evaluate the success of such ads and content.
7. Your Privacy Choices
You have certain choices regarding our processing of your personal information. For example:
- Marketing communications. You can opt out of receiving marketing emails from us by using the unsubscribe link in the footer of each marketing email we send to you.
- Cookie preferences. These preferences are browser and device specific. So, you will need to set your preferences for each browser and device you use, and if you subsequently delete or block cookies you may need to reapply these settings.
If you are a California resident, please review Section 12, “Additional Information for California Residents,” below, for specific information about your California privacy rights and how to exercise them.
For more information about our privacy practices and your privacy choices, you may contact us as set forth in Section 11, “Contact Us.”
8. Children/Minors
Our Services are not designed for children, and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information in violation of applicable law, we will delete such information from our systems. If you are a parent and you believe we have collected your child’s information in violation of applicable law, please contact us as set forth below, in Section 11, “Contact Us.”
9. Security
We have implemented safeguards that are intended to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
10. Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any updates to Policy here.
11. Contact Us
If you have questions about this Policy or our privacy practices, you may contact us at info-mmi@michelin.com.
12. Additional Information for California Residents
This section provides California residents with additional information regarding our collection, use and disclosure of their personal information, as well as their privacy rights, under California privacy laws.
In this section, we use “personal information,” as the term is defined under California Consumer Privacy Act, as amended (“CCPA”). This section does not address or apply to our handling of personal information that is exempt under the CCPA.
Categories of Personal Information Collected and Disclosed. While our processing of personal information varies based upon our relationship and interactions with you, the table below identifies, generally, the categories of personal information (as defined by the CCPA) that we have collected about California residents in the prior 12 months, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose.
Categories of Personal Information |
Description |
Third party disclosures for business or commercial purposes (if any) |
Identifiers | Includes direct identifiers, such as name, user ID, username, email address, IP address and other online identifiers. |
|
Internet and electronic network activity information | Including, but not limited to, browsing history, clickstream data, search history, and information regarding interactions with an internet website, application, or advertisement, including other usage data related to your use of any of our Services or other online services. |
|
Location data | Location information about a particular individual or device. |
We do not share this type of personal information |
Audio, visual and other electronic data | Includes audio, electronic, visual, thermal, olfactory, or similar information such as call recordings of customer support calls. | We do not share this type of personal information |
Professional information | Includes professional and employment-related information, such as current employer business contact information and professional memberships. | We do not share this type of personal information |
Sources of Personal Information. In the preceding 12 months, we have collected the categories of personal information identified in the table above from the following categories of sources:
- Directly from the individuals
- Analytics providers
- Vendors and service providers
Purposes for Collection, Use, and Disclosure. As described in more detail in Section 3, “Purposes of Collection and Processing” and Section 4, “Disclosures of Personal Information” above, we collect, use, disclose and otherwise process the above personal information for the following business or commercial purposes and as otherwise directed or consented to by you:
- Services and support
- Analytics and improvement
- Security and protection of rights
- Legal proceedings and obligations
- In support of business transfers
- Compliance, governance and legal, requirements
Retention. We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection. For example, we will retain your profile and account data for as long as you have an active account with us, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with legal obligations.
Sales and Sharing of Personal Information. The CCPA also requires that we disclose how we ‘sell’ and ‘share’ personal information. Under the CCPA, a ‘sale’ is defined broadly to include disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and ‘share’ broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. In the past 12 months from the Effective Date above, we have not sold California residents’ personal information. However, we have shared the following categories of information with third-party ad networks, including Google Ads, for purposes of cross-context behavioral advertising:
- Identifiers
- Internet and Electronic Network Activity
For more information on these categories, refer to our descriptions in the table above. We do not sell or share any personal information about individuals who we know are under sixteen (16) years old.
Note that, as of October 2022, we no longer share personal information of California residents with third-party ad networks.
California Residents’ Rights. In general, California residents have the following rights with respect to their personal information:
- Do-not-sell or share (opt-out): to opt out of sales and sharing of their personal information. However, as described above, we do not sell or share California residents’ personal information.
- Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.
- Right to know/access: the right to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.
- Right to correct: the right to request that a business that maintains inaccurate personal information about the resident correct that personal information.
- Right to limit: the right to limit our use or disclosure of sensitive personal information to those authorized by the CCPA. We do not collect, use, or disclose sensitive personal information, thus this right is not available.
- Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.
Submitting CCPA Requests. California residents may submit CCPA requests to access/know, correct and delete their personal information maintained by us by sending an email to info-mmi@michelin.com.
We will take steps to verify your request by (i) sending you an email confirmation link which you must click to confirm your request; and (ii) matching the information provided by you with the information we have in our records. You must provide us with the following information: (1) first and last name; (2) email address; and (3) zip code. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.
Authorized agents may initiate a request on behalf of another individual by contacting us at info-mmi@michelin.com; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
For more information about our privacy practices, you may contact us as set forth in Section 11, Contact Us, above.