SUMMARY

1 - Who we are and how to contact us

2 - Our websites covered by this privacy policy

3 - About our privacy service

4 - Other policies we invite you to review

5 - Information we may collect about you

6 - Information about our marketing communications

7 - Information we collect about you from other places

8 - Where we store your personal information

9 - Sharing your personal information

10 - International transfers of your personal information

11 - How long we keep your personal information

12 - Your rights under data protection legislation

13 - What recourse you have if you are not happy with the way we use your information

14 - About data security

15 - Changes to our privacy policy

1. WHO WE ARE AND HOW TO CONTACT US

Our full legal name is AirCaptif and we are the data controller. If you need to contact us, you can do so by various means:

Via the contact form

By e-mail: support@aircaptif.com

2. OUR WEBSITES COVERED BY THIS PRIVACY POLICY

The information in this policy applies to the following websites: www.aircaptif.com

3. ABOUT OUR DATA PROTECTION SERVICE

Although all Michelin employees are committed to protecting and respecting your privacy, we have a personal data protection department in charge of all aspects of personal data at Michelin. You can contact them by sending an e-mail to privacy.fr@michelin.com

4. OTHER POLICIES AND INFORMATION THAT WE INVITE YOU TO CONSULT

This privacy policy contains all the information you need to know about how we collect and use your personal information on our websites, but we encourage you to review information in other places.

- Additional privacy policies

- Our cookie policy

- Related platforms

Additional privacy policies

This document represents our primary privacy policy with respect to the use of the website and the digital products and services offered by AirCaptif. However, additional information may be found in privacy policies specific to certain digital products and services. Please refer to these policies when you register or subscribe to these products or services.

Our cookie policy

When you use our website or other digital products and services we provide, information may be collected via cookies to distinguish you from other users of our website and other digital products and services. We have a separate cookie policy, which details our use of cookies and why we use them. We encourage you to review our cookie policy.

Linked platforms

Our site may contain links to and from the websites and digital platforms of our partner networks, advertisers, affiliates and social networks. If you follow a link to one of these websites, please note that these websites have their own privacy policies and that we cannot be held responsible for these policies. Please check these policies before providing any personal information to these websites.

5. INFORMATION WE MAY COLLECT ABOUT YOU

This section explains:

- how we collect your personal information,

- the categories of data we collect,

- how we plan to use the information we collect,

- the legal basis on which we will process the information we collect,

- how long we will keep the information we collect; and

- the specific types of data.

We may collect and store the following information about you:

Voluntary information

When you provide us with information (for example, the information detailed in the scenarios above), in some cases we will also ask you for additional information on a voluntary basis. This information will be presented as optional and used to help us better understand our customers and to personalise our services.

Statistical information

We also collect and use aggregate data such as statistical or demographic data ("Aggregate Data"). Aggregate Data may be derived from your personal information but does not reveal your identity. For example, we may aggregate your usage and device data to calculate the percentage of our website users accessing a specific feature of our website. Aggregate Data is used solely for our own purposes.

Sensitive Personal Information

Although we do not ask for sensitive personal data, we do have areas on our websites where you can submit additional information, for example, when you submit a review. If you submit information in this free text section, only submit information that you are comfortable providing and always keep in mind that it may be sensitive information. If you submit comments or suggestions on our website, please keep in mind that this information will be visible to other users of our website.

6. INFORMATION ABOUT OUR MARKETING COMMUNICATIONS

You will only receive marketing communications from us if you choose to receive them.

When you sign up to receive our newsletters or marketing communications, we use the information you provide, usually your name and email address, to enable us to send you our newsletters, promotions and other marketing communications.

We will process your personal information for marketing purposes on the basis of your consent. You can withdraw your consent at any time and we will stop sending you our newsletters, promotions and other communications as requested.

Thus you can unsubscribe at any time either:

(I) by clicking on the unsubscribe link at the bottom of each marketing communication we send you; or

(II) by contacting us by email or post using one of our contact details set out in paragraph 1.

We may send you marketing communications until you decide to unsubscribe from receiving them. However, if for a period of 3 years we have not heard from you or if we notice that you have not opened our emails, we will remove your details from our database. There is nothing to stop you from resubscribing at any time.

From time to time, we may also use your usage and terminal data to make online suggestions and recommendations to you about goods or services that may be of interest to you. This processing is based on our legitimate interest in developing our products and services.

7. INFORMATION WE COLLECT ABOUT YOU FROM OTHER PLACES

To enable us to provide our services to you, we may receive personal information about you from other sources:

We may receive information about you if you use any of the other websites we operate or the other products and/or services we provide. We also work closely with third parties (including, for example, business partners, technical contractors, payment services, analysts, research information providers) and may receive information about you from them.

The legal basis for this processing is our legitimate interest in monitoring and improving our website, products and services.

Information from our web server logs, for example information about your computer, such as your IP address, operating system or browser type. We may also collect information about the searches you perform on our website and your interaction with communications we send to you, for example when you open email communications ("Usage and Terminal Data"). We use this information for system administration and analysis of how our websites and digital platforms are used. It also enables us to provide the best online infrastructure for your digital activities.

The legal basis for this processing is our legitimate interest in monitoring and improving our website, products and services.

As mentioned above, we collect information, using cookies or similar technologies stored on your terminal, about how you use our website and our digital products and services. Cookies contain information that is transferred to the hard drive of your computer or mobile phone/tablet. They enable us to improve our websites and provide you with a better and more personalised service. You can read our cookie policy.

The legal basis for this processing is your consent or, where applicable, our legitimate interest in monitoring and improving our website, products and services.

Our website may allow you to share your experience and communicate with us through third party social networks such as Facebook and Twitter. We may collect this information on our social networking sites, including likes, shares and tweets, as well as content on the social networking sites. We do not control the privacy of the information you provide on social networks and the privacy policies of those social networks will apply when using their services.

The legal basis for this processing is your consent.

8. WHERE WE STORE YOUR PERSONAL INFORMATION

All information you provide to us is stored on secure servers in the EEA.

Although we are committed to protecting your personal information, the transmission of information online via the Internet is not completely secure. We, along with our service providers, will do our best to protect your personal information, but the information provided is at your own risk.

9. SHARING YOUR PERSONAL INFORMATION

Your personal data will only be passed on to those who need to know that information to carry out their duties.

We may share your personal data in the following ways:

Within the Michelin Group

We may disclose your personal information to any member of our group, i.e. our subsidiaries, the ultimate parent company and its subsidiaries, to the extent necessary for the same purposes as the original processing set out in this policy.

To subcontractors

AirCaptif may share your personal data with subcontractors that the group may use to process your request or provide services. These subcontractors are contractually bound to ensure the confidentiality and security of the personal data received and to process your personal data only on our instructions.

To third parties

(I) For legal reasons

If we are under a duty to disclose or share your personal information in order to comply with a legal obligation, or to enforce or apply our terms and conditions of use or any other contract; or to protect our rights, property or the safety of the Michelin Group, its customers or others. In this context and to the extent necessary, we may pass your personal information to any external counsel who would be bound by an obligation of confidentiality.

(II) On the basis of your consent

Third parties may collect information about you on our website, products or services via cookies or similar technologies, for example to deliver personalised advertisements or to perform profiling. These cookies will be handled in accordance with our Cookie Policy.

10. INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION

Michelin is an international group with databases in the various countries where it is present. Michelin may transfer your personal data within the group to one of its databases or to one of its external partners located in a country other than yours.

As the level of data protection varies from country to country, we will only transfer your personal data to companies within the Michelin Group or to third party companies outside the European Union if they offer the same level of protection for personal data as Michelin.

For transfers within the Michelin Group, the company has adopted internal rules governing the transfer of personal data from the European Union or the European Economic Area (EEA). By clicking on "BCR", you will find details of the rules.

Transfers of data outside the Group are governed either by our processor's BCRs or by contracts containing the European Commission's clauses, for suppliers based outside the EU to ensure a similar level of protection to your home country.

Although we are committed to ensuring the security of your personal information, the transmission of information online via the internet is not completely secure. In conjunction with our service providers, we are committed to doing everything we can to protect your personal information, but the provision of information is at your own risk.

11. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

By default, we will not retain your personal information for longer than is necessary for the purposes for which we collected it, for any purpose, including for the purpose of satisfying any legal, accounting or reporting requirements. For more specific information on how long we retain your personal information, please see paragraph 5 of this policy.

In determining the appropriate retention period for personal data, we take into account the amount, nature and sensitivity of the personal data, the potential risk of unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, our potential ability to pursue those purposes through other means and any applicable legal requirements.

In certain circumstances you may ask us to delete your data: see your right to deletion below for more information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. In this case, we may use the information indefinitely without notifying you.

12. YOUR RIGHTS UNDER THE DATA PROTECTION REGULATIONS

The Data Protection Regulation gives you certain rights regarding the processing of your information. These rights are as follows:

- The right to be informed

- The right to access your information

- The right to correct your information

- The right to delete your information

- The right to restrict processing

- The right to portability

- The right to object to processing

- The right to determine the fate of your data after your death

The right to be informed

You have the right to be informed about how we collect and process your personal information, including who we are, how we use your personal information and your rights in relation to your personal information. We have put together all the necessary information in this privacy policy.

The right to access your information

You have the right to access the personal information we hold about you. We can confirm whether or not your information is being processed and give you access to your personal information.

The right to correct your information

If your personal information is inaccurate or incomplete, you are entitled to have it corrected and updated. If we have disclosed your information to third parties, where possible, we will inform them of any updates you have provided to us. You may update the personal information we hold about you by contacting us via the contact methods set out in this Privacy Policy.

The right to delete your information

You have the right to request the deletion or removal of your personal information if we have no reason to continue processing it. The circumstances in which you can invoke the right to be forgotten include situations where the information is no longer necessary for the purpose for which it was originally collected or processed and situations where you have withdrawn your consent to processing.

In certain limited circumstances, the right to be forgotten does not apply. If you want to know more, please ask us.

The right to restrict processing

You have the right to 'block' or prevent the processing of your personal information. If you ask us to delete your personal information, we will stop processing it.

The right to portability

If you wish to move or transfer your personal information to another service provider or copy your information for your own reasons, you have the right to have your information transferred to another person.

The right to object

You have the right to ask us not to process your personal information for marketing purposes. Usually we will inform you (before we collect your data) if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your information. You can also exercise this right at any time by contacting us.

The right to determine what happens to your data after your death

You also have the right to tell us what you want us to do with your data after your death. We will record and, if we become aware that such an event has occurred, respect your instructions.

You can find more information about your data protection rights with the CNIL on their website www.cnil.fr.

13. THE REMEDIES AVAILABLE TO YOU IF YOU ARE NOT SATISFIED

We are committed to protecting and respecting your privacy. However, if you are not happy with the way we collect or process your information, or if you would simply like more information about your rights, you can contact us in the following ways:

Send an email to privacy.fr@michelin.com

Contact via the contact form

We will endeavour to resolve any issues you may have with us and answer any questions you may have as soon as possible.

If, after contacting us, you feel that your rights have not been respected or that the access control system does not comply with data protection rules, you can submit a complaint to the CNIL.

14. ABOUT DATA SECURITY

Michelin has implemented measures to protect the confidentiality, security and integrity of your personal data. Access to personal data is restricted to employees and service providers who need to know this information and who have been trained to comply with confidentiality rules.

On Michelin's commercial sites, banking information will be collected in order to provide efficient, legal and secure payment processes. These measures may consist of SSL encryption (the purpose of which is to make the data unreadable by third parties) during the collection or transfer of confidential data. The information mentioned will only be used for online payment and will not be stored.

Michelin undertakes to ensure that your personal data will not be altered or damaged and that unauthorised third parties will not have access to it.

15. CHANGES TO OUR PRIVACY POLICY

We may make changes to our policy from time to time. Any future changes to this policy will be posted on this page. If you have an online account with us, we may notify you of any changes by email or through your account the next time you log in.