privacy policy

Abstract

APR is committed to protecting your personal information and taking a clear and transparent approach to the information we collect and how we use it. This policy explains how we treat the personal information we collect, or that you provide to us, when you use our website or digital services.

Please read the policy below carefully to understand our views and practices regarding your personal information and how we will treat it.

  • Who we are and how to contact us
  • The web site covered by this privacy policy is
  • About our data protection officer
  • Other policies we invite you to consult
  • Information we may collect about you
  • Information about our marketing communications
  • The information we collect about you from other places
  • Where do we store your personal information?
  • Sharing your personal information
  • International transfers of personal data
  • The period of time we keep your personal information
  • Your rights under data protection law
  • Your recourse if you are not satisfied with the way we use your information
  • About data security
  • Changes to our privacy policy

1 – Who are we and how to contact us?

Our full legal name is Auvergne Pneumatiques Racing (“APR”) and when you use our website or our services, we are the data controller. If you need to contact us, you can do so by different means :

2 – The web site concerned by this policy on personal data

The information presented in this policy applies to the website https://trackconnect-pro.michelin.com.

3 – About our data protection officer

Although all APR employees are committed to protecting and respecting your privacy, we have a Data Protection Officer in charge of all aspects related to personal data at APR. You can contact them by sending an e-mail to apr-contact@apr-europe.com.

Other policies and information that we invite you to read

This Privacy Policy contains all the information you need about how we collect and use your personal information on our websites, but we encourage you to review information that can be found elsewhere:

  • Our cookie policy
  • Terms and conditions of use of our website
Our Cookie Policy

When you use our website or other digital products and services that 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 the reason we use them. We encourage you to review our cookie policy here.

Terms and Conditions of Use

The terms of use of our website indicate the conditions under which you may use our websites and should be read in conjunction with this privacy policy. You can read the terms and conditions of use of our website here.

4 – The information we may collect about you

This section presents :

  • 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 collected,
  • The length of time the information collected is kept; and
  • Specific types of data.

We may collect and store the following information about you:

Collected data Purposes Data type Legal basis of the processing operation Shelf life
If you sign up for one of our digital products or services via an account, we will request information that allows us to identify you and provide you with the products and services in question.

(“Account Data”)

 

Account Data will be processed for the purposes of operating our website, providing you with the digital services to which you have subscribed, communicating with you about these digital products and services, and making backups of our services. The Account Data will include your email address, VAT number and a password to allow you to securely log in to your account. The execution of the agreement between you and us for the provision of digital products and services is the legal basis for the processing of Account Data. We retain Account Data for as long as the account exists. If you do not access your account for more than 24 months, we will delete the Account Data so that we do not retain the Account Data longer than necessary. You can of course create a new account if you wish.
When you make a purchase on our website, we collect data related to the transaction and the goods or services purchased.

(“Transaction Data”)

Transaction data will be used to carry out operations related to orders, deliveries, after-sales service, etc. Transaction data will include your first name, last name, postal and e-mail address, telephone details, delivery details, VAT number, company name. These treatments are based on the execution of the contract. Your information will be kept for the duration of the contractual relationship plus 5 years for invoicing data.
The information you provide us with when you communicate with us, for example by e-mail or via the contact form on our website.

(“Communication Data”)

This information is used to enable us to respond or follow up on your comments, requests or questions. The information may include your full name, e-mail address and other personal data that you provide to us to enable us to process your communication. We will use our legitimate interest in assisting you and answering your questions as the legal basis for the processing of the Communication Data. We will retain the Communication Data for as long as necessary to enable us to deal with the matter relating to that communication. Once we have dealt with your issue, we will delete the Communication Data within 6 months.
If you let us know that you would like to receive additional information by subscribing to one of our newsletters or marketing communications.

(“Marketing Data”)

For more details, refer to paragraph 6 of this policy.

Marketing Data is processed for the purpose of sending you notifications and/or newsletters and/or any marketing communication. We will ask you for your name and e-mail address so that we can send you the requested information. The legal basis for this processing is consent.

 

Your information will be kept for a period of 3 years after the last contact.
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 enable us to better understand our customers and to personalize 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 Terminal Data to calculate the percentage of our website users accessing a specific feature of our website. Aggregated Data is used only for our own purposes.

Sensitive Personal Information

Although we do not request sensitive personal data, we do have sections on our websites where you can submit additional information, for example, when you submit a review. If you submit information to 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 about our website, remember that this information will be visible to other users of our website.

Minors and personal information

Our website is not directed at minors and we do not knowingly collect information from minors. If we become aware that we hold any information about a minor under the age of 15, we will take all necessary action to comply with applicable regulations on the protection of personal data, including, if necessary, the deletion of such information.  If you have learned that your minor child has provided us with personal information without your permission, please contact us as soon as possible at apr-contact@apr-europe.com so that we can take appropriate action.

5 – Information about our marketing communications

You will only receive marketing communications or newsletters from us (i) if you wish to receive them, (ii) if you are already one of our customers, provided that the communication relates to similar services or products, or (iii) if the communication relates to your business.

In this context, we use the information you provide us, usually your name and e-mail address.

In any case, you can unsubscribe or stop any commercial prospecting on our part 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 e-mail 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. Nothing prevents you from resubscribing at any time.

6 – The information we collect about you from other places we collect information about you

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

  • We may receive information about you if you use one 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) 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 the communications we send to you, for example, when you open e-mail communications. (“Usage and Terminal Data”). We use this information for system administration and to analyze how our sites and digital platforms are used. It also enables us to provide the best online infrastructure for your digital business.

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 to provide you with a higher quality and more personalised service. You can view our cookie policy here.

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, Instagram, Twitter, Linkedin and Youtube. We may collect this information on our social networking sites, including likes, likes, shares and tweets, as well as the content on social networking sites. We do not control the privacy of the information you provide on social networks and the personal data policies of these social networks will apply when using their services.
  • Information about you from other reliable sources. This information will be collected from publicly accessible files, such as the European VAT number file.

7 – Where do we store your personal information?

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

8 – Sharing your personal information

Your personal data will only be passed on to people who need to know this information in order to carry out their tasks.

We may share your personal data in the following ways:

  • Within the Michelin Group

We may disclose your personal information to any member of the Michelin Group, i.e., subsidiaries, the ultimate parent company and its affiliates, to the extent necessary to fulfill the same purposes as the initial processing set forth in this policy.

  • To subcontractors

APR may share your personal data with subcontractors that the Group may use to process your request or provide services, including IT and system administration services such as hosting, email services and the management of notices and reviews. These processors are contractually bound to maintain the confidentiality and security of the personal data they receive and to process your personal data only on our instructions.

  • To third parties
  • For legal reasons

If we are required to disclose or share your personal information in order to comply with any 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 APR Group, its customers or others. In this context and to the extent necessary, we may disclose your personal information to any outside counsel who is bound by an obligation of confidentiality.

  • On the basis of your consent

Third parties may collect information about you on our website, products or services through cookies or similar technologies, for example to serve personalized advertisements or for profiling purposes. These cookies will be processed in accordance with our Cookie Policy. You can read about it here.

9 – International transfers of personal data

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

10 – The length of time we keep your personal information

By default, we will not retain your personal information longer than is necessary to fulfill the purposes for which we collected it, regardless of the 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 refer to paragraph 5 of this Policy.

In determining the appropriate retention period for personal data, we take into account the amount, nature and level of sensitivity of the personal data, the potential risk represented by any unauthorized 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 applicable legal requirements.

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

In certain 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 this information indefinitely without informing you.

11 – Your rights under data protection regulations

Data protection regulations allow you to have 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 limit processing
  • The right to portability
  • The right to object to the processing
  • The right to determine the fate of your data after your death

For more information on your rights :

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 collected 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, to the extent possible, we will inform them of any updates you have provided us with. You can update the personal information we hold about you by contacting us using 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. Circumstances in which you may invoke the right to oblivion 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 the processing.

In certain limited circumstances, the right to forget does not apply. If you would like to know more, please ask us.

The right to limit processing

You have the right to “block” or prevent the processing of your personal information. If you ask us to remove your personal information, we will stop the processing of your personal information.

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 purposes, 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 ticking certain boxes on the forms we use to collect your information. You may also exercise this right at any time by contacting us at apr-contact@apr-europe.com.

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

You also have the right to tell us what you would like us to do with your data after your death. We will record and, if we learn that such an event has occurred, comply with your instructions.

12 – The remedies available if you are not satisfied

We are committed to protecting and respecting your privacy. However, if you are not satisfied with the way we collect or process your information, or if you simply wish to obtain more information about your rights, you can contact us via the following means:

We will work with you to resolve any problems you may encounter and answer any questions you may have as soon as possible.

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

 13 – About data security

APR 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 have a need to know such information and who have been trained to comply with confidentiality rules.

On APR’s commercial sites, banking information will be collected for the purpose of providing 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 retained.

APR undertakes to ensure that your personal data is not altered or damaged and that unauthorised third parties do not have access to it.

14 – Changes to our personal data 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 via your account the next time you log in.

 

Date: 06/05/2020