ONTRAIL PRIVACY NOTICE
Last Updated: March 22, 2021
This Privacy Notice explains how we collect, use, disclose, and otherwise process personal information from users of our website, software, application and other services (collectively the “Services”).
Who We Are: BFGoodrich Tires is a brand of Michelin North America, Inc. (“MNAI”, “we”, “us”, or “our”) with operations throughout the United States.
Our Services: When we use the term “Services”, we are referring only to the OnTrail website, OnTrail application, or other services that post or link to this Privacy Notice. The HyperDrive Rewards program OR SideCart Rewards program (“Rewards Program”) through which you access and use the OnTrail Rewards Program are provided by our third-party service provider, Connected Travel, LLC.
This Privacy Notice does not cover or address, for example:
• Any of MNAI’s other product or service offerings, including other websites and mobile applications that do not post or link to this Privacy Notice. To learn more about MNAI’s personal information practices relating to these other product or service offerings, please visit their respective privacy notices and policies.
• Personal information and privacy practices relating to MNAI job applicants, employees and other personnel.
• Privacy practices of independent third-party retailers that sell MNAI products.
Your use of the Services is subject to this Privacy Notice and our Terms of Use. If you do not agree with any term in this Privacy Notice, please do not use the Services or submit any personal information. Please read the following notice carefully to understand our views and practices regarding your personal information and how we will treat it.
Users Outside of North America
If you are a non-U.S. user of the Services, by using our Services and providing us with your personal information, you agree and acknowledge they your personal information may be processed for the purposes identified in this Privacy Notice. Your personal information may be processed in the country in which it was collected and in other countries. By using the Services, you consent to such transfer and the application of the laws of the United States, which may not be as protective or comprehensive as those that exist in your home country.
Region-Specific Disclosures
Depending on your country, province or state of residence certain rights may apply to you. Please refer below for disclosures that may be applicable to you:
- If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.
- If you are a resident of the State of Nevada in the United States, the following applies for Nevada-specific privacy disclosures:
Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please use this webform to opt out of the sale of covered information.
What is Personal Information?
When we use the term “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to a person.
1. Our Collection of Personal Information
We collect personal information about you in a variety of ways. Sometimes we collect personal information automatically when you interact with the Services, and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction. We may link or combine your activities and information collected from you related to the Service with information we have collected from you offline (e.g., at an event), information we receive from third parties, as well as information we collect automatically through tracking technologies (as discussed in the Cookie Notice).
Personal Information You Provide
We may collect the following personal information you provide in connection with our Services:
- Contact Information, including your name, email address, date of birth, phone number, gender, emergency contact phone number, address, and zip code when you register or create an account for the Services.
- Payment and Transaction Information, including information collected on products purchased, the third-party from whom you purchased a product, date and time of your transaction, amount purchased, order details, whether you used a particular coupon or promotion, and any payment information when you make a purchase or transaction. Payments may be processed by third-party payment processors and MNAI may have not access to such payment information. Please refer to the applicable processor’s terms and privacy notice for more information about how payment information is processed and stored.
- Inquiry and Communication Information, such as your name and email address as well as the content of your email
- Sensory Information, including pictures you provide or upload in connection with the Services, and the content and audio recordings of phone calls between you and MNAI and you and our service providers, that we record where permitted by law.
- Demographic Information, including age.
- Account Information, including your username and password and other information requested on the account registration page. We will save default or preference settings you create and any calendar or other information you provide, import, or make available to the Services. We may collect information regarding other loyalty programs to which you belong (e.g. a gas station loyalty program) if you import or make this information available to the Services.
- Vehicle and Tire Information, including vehicle type, make, model and year, tire make and model and tire installation date.
- Professional/Employment Information, including your job title, department, employer or business, and trade or professional association membership information.
- Location Information, including information from your device as well as the software installed in your vehicle related to your mode of transportation, vehicle operations, your phone, and your habits, including without limitation, driving behavior. For example, we may collect information about whether you are walking or driving; whether you are on your phone while driving; your place or origin and destination; what time you leave your place of origin and arrive at your destination; the number of times you brake; how hard you brake; how often you speed and the difference between your vehicle speed and the posted speed limit; your position; direction of travel; speed; acceleration; deceleration, etc.
- We may also collect personal information at other points in the Services that indicate that personal information is being collected.
Personal Information Automatically Collected
As is true of most digital platforms, we may collect certain personal information automatically when you use the Services, including:
- Log File Data, including your IP address, unique identifiers, device type, screen size, operating system, browser type, browser id, language settings, date/time of visit, pages visited, memory capacity, plug-ins, TCP configuration parameters, carrier code, time zone and the names, versions and package IDs of software installed on your device.
- Analytics Data, including the path you take to the Services, through the Services and when exiting the Services, as well as your usage and activity on the Services, such as the links and content you view, click or otherwise interact with (also known as “Clickstream Data”), search terms you enter using our Services or on a referral site, unique identifiers. For additional information, please visit our Cookie Notice.
- Location Data, including your general geographic location based on your IP address or more precise location when accessing our Services through a mobile device. We may also use the Google Maps Application Programming Interface to gather information about your location. Google uses various technologies to determine your location, including your IP address, GPS, and other sensors that may, for example, provide Google with information on nearby devices, Wi-Fi access points, and cell towers (see Google Maps’ privacy policy here to learn more).
- Information You May Post/Submit to our Services. We may collect information about how you use and interact with our Services, including any information and content you post to the Services. If you share photos and video from a mobile device, we will access your device camera roll and camera with your permission as needed to post your content. If you need to update your permissions, you can do so in the Settings app of your device.
For information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to its collection, please visit our Cookie Notice.
Personal Information Provided by Other Sources
We also may obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you.
We may receive the same categories of personal information as described above from the following sources and third parties:
- Our Brands. We may receive information about you from our other brands and affiliates, so that information you provide to one brand or affiliate may be used by us to provide you Services, communication with you or provide you advertisements or other personalized content.
- Service Providers: Our service providers that perform services solely on our behalf, such as our call center operations vendors, identity verification providers, payment processors, and analytics providers.
- Business / Promotional Partners: Our business and promotional partners whom we partner with to provide our contests, sweepstakes or other joint promotional activities or co-branded services may collect personal information in connection with these activities and may share some or all of the information with us.
- Social Networks: When you interact with the Services through various social media networks, such as when you “Like” us on Facebook or when you follow us or share our content on Facebook, Pinterest, Twitter, Instagram, YouTube or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third party websites and social media networks and services before linking or connecting them to the Services.
- Other Third Parties and Publicly Available Sources: From time to time, we may receive information about you from third parties. For example, we may obtain information from our marketing partners or from third parties to enhance or supplement our existing user information. We may also collect information about you that is publicly available, including contact information, employment-related information, and product interest information. We may combine this information with the information we collect from you directly.
2. Our Use of Personal Information
We may collect, use and disclose your personal information for purposes identified at the time of collection, or as otherwise permitted or required by law, including the following purposes:
- To create and administer your account.
- To provide you with feedback on your driving safety so that you may improve the safety for you and your passengers.
- To provide you with the Services and customer support, including administering the Rewards Program and any other promotional programs we may provide.
- To provide you with the Rewards Program and location-based rewards offers.
- To personalize your experience and customize content on the Services relevant to your interests, including but not limited to targeted offers and ads through our websites, email, social media channels, third-party sites, or on other devices you may use.
- To provide improved administration of the Services.
- To communicate with you and respond to your requests, resolve disputes and/or troubleshoot problems.
- To operate, maintain, and provide the features and functionality of the Services.
- To conduct surveys and questionnaires to evaluate and improve the Services.
- To complete the performance of the Services pursuant to an agreement between you and us.
- To send you important information regarding the Services, such as welcome emails when you create an account or join the Rewards Program, offers for products and services you may be interested in and administrative notifications such as any changes to our terms, conditions, policies, and/or other administrative information. Because this information may be material to your use of the Services, you may not opt out of receiving such communications.
- To inform you of products, programs, services and promotions that we believe may be of interest to you, including, without limitation, adding you to our email/mailing lists and permitting you to participate in sweepstakes, contests, rebates and similar promotions (collectively, “Promotions”) or following up with you if you are the winner for a promotion.
- To evaluate your eligibility for certain types of Promotions, offers, products or services that may be of interest to you. To help maintain the safety, security, and integrity of the Services, technology assets, and business.
- For our internal business purposes, such as data analysis, customer research, audits, fraud prevention, developing new products and/or features, evaluating the Services, enhancing the Services, improving the Services and identifying usage trends, and determining the effectiveness of Services, including to inform our machine learning for purposes such as user engagement.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations and enforce our corporate reporting obligations and our Terms of Use, or to comply with applicable laws.
- For purposes disclosed at the time you provide your personal information or as otherwise set forth in this Privacy Notice.
We will only keep your personal information for as long as necessary to fulfill the purpose for which it was collected or as otherwise required by applicable law.
We may also use aggregate personal information in a manner such that the end-product does not uniquely identify you or any other user of the Services, for example to compile statistics about the Services based on responses to our product surveys or questionnaires.
We may provide additional privacy disclosures where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.
3. Our Disclosure of Personal Information
We may disclose your personal information for purposes and uses that are consistent with this Privacy Notice in the following ways:
- Within MNAI: We may disclose personal information between and among MNAI and its current and future parents, affiliates, subsidiaries, our brands, and other companies under common control or ownership.
- International Transfers of Personal Data: Michelin is an international group with activities around the world. We may transfer your personal data as described in this Privacy Notice to a country other than where we originally collected it. However, when we transfer your information to other countries, we will protect that information as described in the Privacy Notice and take steps, where necessary, to ensure that international transfers comply with applicable laws.
- Business / Promotional Partners: We may share limited information with third parties with whom we partner that sponsor or offer a rewards program or provide contests and sweepstakes, or other joint promotional activities or co-branded services.
- Online Advertising Partners: We also share personal information with advertising networks or permit these partners to collect information from you to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms. For more information, including how to opt out of interest-based advertising, please read our Cookie Notice.
- Service Providers: We share personal information with third-party vendors, consultants, and other service providers whom we engage to perform functions or services on our behalf and under our instructions in connection with the purposes and uses described in this Privacy Notice. Such service providers are under contractual obligations to maintain the confidentiality of your personal information and to use such information only pursuant to our instructions.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership, in compliance with applicable law.
- Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
· in connection with the establishment, exercise, or defense of legal claims;
· to comply with laws or to respond to lawful requests and legal process;
· to protect the rights and property of MNAI, our agents, customers, and others, including to enforce our agreements, policies, and Terms of Use;
· to detect, suppress, or prevent fraud;
· to reduce credit risk and collect debts owed to us;
· to protect the health and safety of us, our customers, or any person; or
· as otherwise required by applicable law.
- With Your Consent or At Your Direction: We may disclose personal information about you to certain other third parties with your consent or at your direction.
4. Children’s Personal Information
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 15. If you are under the age of 15, please do not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 15 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 15, we will promptly delete that personal information.
5. Third-Party Websites
Our Services may include links to third-party websites, plug-ins, and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
6. Choices and Control Over Your Information
How to control your email preferences: When you create an Account and provide your email address, we will occasionally send you account related emails, newsletters and emails that directly promote the use of the Services and our other products and services and our business partners’ products and services. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the service, technical and security notices). You may also be able to adjust certain communications preferences by logging into the Preference Center.
Online advertising and tracking: Please refer to our Cookie Notice to learn more about how we work with third party partners to collect data through tracking technologies for various purposes, including analytics and advertising, and to understand your choices.
7. Safeguarding Your Information
Your privacy is very important to us and shall be protected by security safeguards appropriate to the sensitivity of the information. We use leading security technology and security procedures to protect your personal information against loss, theft, unauthorized access, copying, use, modification or disclosure. Among other techniques, we usually store such information on a computer behind our firewall to ensure that only the necessary employees internally can access this data. Of course, there is no such thing as perfect security on the internet and we cannot guarantee the security of any information you disclose over the internet.
8. Updates to This Privacy Notice
Even though our information practices may change from time to time, we will not use your information in a manner not previously disclosed to you in our Privacy Notice. When we make changes to this Privacy Notice, we will change the "Last Updated" date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by email to your registered email address, by prominent posting on through the Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
9. Accountability and Contact
MNAI is
responsible for personal information under its control and has a designated
privacy officer who is accountable for the organization’s compliance with
applicable privacy laws and regulations in North America. If you have any
questions or requests in connection with this Privacy Notice or other
privacy-related matters, please send an email to Privacy.AMN@michelin.com.
Alternatively, inquiries may be addressed to:
Michelin North America Privacy Officer
One Parkway South
Greenville, SC 29615
COOKIE NOTICE
Last Updated: March 5, 2021
Unless otherwise expressly stated, capitalized terms in this Cookie Notice have the same meaning as defined in the Privacy Notice.
1. Scope of Notice
This Cookie Notice supplements the information contained in the Privacy Notice by explaining how we and our business partners and service providers use cookies and related technologies in the course of managing and providing our services and our communications to you. It explains what these technologies are and why we use them, as well as your rights to control our use of them.
In some cases, we may use cookies and related technologies described in this Cookie Notice to collect personal information, or to collect information that becomes personal information if we combine it with other information. For more details about how we process your personal information, please review the Privacy Notice.
2. Cookies and Related Technologies
Cookies are small data files that are stored on your computer that allow us and our third-party partners and providers to collect certain information about your interactions with our email communications, websites and other services. We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).
3. What We Collect When Using Cookies
We and our third-party partners and providers may use cookies to automatically collect certain types of usage information when you visit or interact with our email communications, websites and other services. For example, we may collect log data about your device and its software, such as your IP address, operating system, browser type, date/time of your visit, and other similar information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure usage and activity trends for our online services and better understand our customer base.
Third-party partners and providers may also collect personal information about your online activities over time and across different websites when you use our websites and online Services.
4. How We Use Information Collected Through Cookies
We use or may use the data collected through cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our websites and services; (b) provide and monitor the effectiveness of our websites and services; (c) monitor online usage and activities of our websites and services; (d) diagnose errors and problems with our websites and services; (e) otherwise plan for and enhance our services; and (f) facilitate the purposes identified in the Our Use of Personal Information section of our Privacy Notice. We and our advertising partners also use the information we collect through cookies to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver ads and information about products and services that may be of interest to you.
Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described in our Privacy Notice.
5. Your Choices About Cookies
You can learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy here. You can also view Google’s currently available opt-out options here.
6. Third-Party Data Collection & Interest-Based Advertising
We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on the services, on other websites, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”), which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider. See “Your Choices About Online Ads” below, to learn more about interest-based advertising.
Social Media Widgets and Advertising. The services may include social media features, such as the Facebook Like button, Pinterest, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to the services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, YouTube and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in the services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks. You may learn more about advertising preferences by clicking on the links provided below. Please note that these links are provided for your convenience only and we do not control the content or features that may be available on these third-party services.
- Facebook. To learn more about your advertising preferences on Facebook Companies, click here
- Twitter. To learn more about privacy controls for personalized ads on Twitter, click here
Third Party Partners. The following is a sample of the third-party service partners we work with to provide advertising services. We will strive to update this list if or when we work with new partners which offer you choices about the collection of your information, but as partners change and new technologies become available, this list is likely to change over time and may not always reflect our current partners.
- Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our websites or services on your browser or mobile device, log in to your account on the services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with the services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting the Network Advertising Initiative’s (NAI) online resources at http://www.networkadvertising.org/choices.
7. Your Choices About Online Ads
We support the self-regulatory principles for online behavioral advertising (Principles) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices, or http://www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again. If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.
For California Residents: By visiting www.privacyrights.info or www.optout.privacyrights.info/?c=1, you can opt out from sales of this type of personal information by businesses that participate in the DAA’s CCPA App-based Opt-Out Tool. To make opt-out requests related to mobile apps on your device for businesses participating in the opt out tool, you can download the appropriate app at https://www.privacyrights.info/appchoices. For more information, please click here for additional California-specific privacy disclosures.
Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.
8. Updates to This Cookie Notice
We will update this Cookie Notice from time to time. When we make changes to this Cookie Notice, we will change the "Last Updated" date at the beginning of this Notice. If we make material changes to this Notice, we will notify you by email to your registered email address, by prominent posting on this website or our services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
9. Contact Us
If you
have any questions or requests in connection with this Cookie Notice or other
privacy-related matters, please send an email to Privacy.AMN@michelin.com.
Alternatively, inquiries may be addressed to:
Michelin North America Privacy Officer
One Parkway South
Greenville, SC 29615
BFGOODRICH ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES
Last Updated: March 5, 2021
1. Scope of Disclosures
These Additional California Privacy Disclosures (the “California Disclosures”) supplement the information contained in our Privacy Notice regarding the BFGoodrich OnTrail website, mobile application, and services and apply solely to individual residents of the State of California (“consumers” or “you”).
These California Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).
Unless otherwise expressly stated, all terms in these California Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.
2. Personal Information Disclosures
When we use the term “personal information” in these California Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
For the purposes of these Disclosures, personal information does not include:
- Publicly available information from government records.
- Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
- Information excluded from the CCPA's scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
- Information relating to our job applicants, employees, contractors and other personnel.
Collection and Use of Personal Information
In the last 12 months, we may have collected the following categories of personal information from the categories of sources and for the purposes set forth below the table, which reference the personal information, sources and purposes described in the Our Collection of Personal Information, Our Use of Personal Information and Our Disclosure of Personal Information sections of our Privacy Notice:
|
Category of Personal Information |
Collected |
|
Identifiers, such as your name, email address, telephone number, address, zip code, account username and password, or other similar identifiers, such as an online identifier or other persistent identifier which can be used to recognize a consumer device over time and across different services |
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California Customer Records (Cal. Civ. Code § 1798.80(e)), such as name, physical characteristics or description, address, phone number. |
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Protected Classification Characteristics, such as age. |
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Commercial Information, such information about products or services purchased or considered, the third-party from whom you purchased a product, date and time of your transaction, amount purchased, order details, whether you used a particular coupon code or promotion, payment information when you make a purchase or transaction, and information about your use of the Services. Payment may be processed by third-party payment processors and MNAI may not have access to such payment information. |
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Biometric Information, such as facial geometry used for identity verification purposes. |
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Internet/Network Information, such as your browsing history, log and analytics data, search history and information regarding your interaction with our Services. |
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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. |
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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 us, that we record where permitted by law. |
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Professional/Employment Information, such as job title, department, employer or business, and trade or professional association membership information. |
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Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99) |
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Other Personal Information, 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 vehicle type, make, model and year, tire make and model and tire installation date. |
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Inferences, including information generated from your use of the Services reflecting predictions about your interests and preferences. |
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Sources of Personal Information
We collect personal information about you from one or more of the following sources:
- Directly from you
- Indirectly from you
- Our Brands and affiliates
- Service Providers
- Business / Promotional Partners
- Social Networks
- Your browser or device
- Generated or derived from other personal information
Please note: In addition to the categories of sources identified above, we may collect information from publicly available sources and other third-party information providers in order to supplement the information we have otherwise collected.
Purposes for Collecting Personal Information
We collect, use, sell or disclose personal information about you for one or more of the following purposes:
- To fulfill or meet the reason the information was provided, such as to process your requests, to create and administer your account, to respond to inquiries, resolve disputes and/or troubleshoot problems, and provide you with feedback on your driving safety so that you may improve the safety of you and your passengers.
- To provide you with the services and customer support, including administering the Rewards Program and any other promotional programs we may provide.
- To provide you with Rewards Program and location-based information and rewards offers.
- To conduct surveys and questionnaires to evaluate and improve the services.
- To personalize your experience and customize content on the Services relevant to your interests, including but not limited to targeted offers and ads through our websites, email, social media channels, third-party sites, or on other devices you may use.
- To provide improved administration of the Services
- To operate, maintain, and provide the features and functionality of the Services.
- To send you important information regarding the Services, such as welcome emails when you create an account or join the Reward Program, offers for products and services you may be interested in and administrative notifications such as certain changes to our terms, conditions, policies, and/or other administrative information.
- To inform you of products, programs, services and promotions that we believe may be of interest to you, including, without limitation, adding you to our email/mailing lists and permitting you to participate in sweepstakes, contests, rebates and similar promotions or following up with you if you are the winner for a promotion.
- To evaluate your eligibility for certain types of promotions, offers, products or services that may be of interest to you.
- To help maintain the safety, security, and integrity of the Services, technology assets, and business.
- For our internal business purposes, such as data analysis, customer research, audits, fraud prevention, developing new products and/or features, enhancing the Services, improving the Services and identifying usage trends, and determining the effectiveness of our services, including to inform our machine learning for purposes such as user engagement.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations and enforce our corporate reporting obligations and our Terms of Use, or to comply with applicable laws.
- For purposes disclosed at the time you provide your personal information or as otherwise set forth in our Privacy Notice.
Disclosure of Personal Information
As described in our Privacy Notice, we share personal information with a variety of third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales (see The Right to Opt-Out of Personal Information Sales below). We disclose personal information to the following categories of third parties:
- Within MNAI and our Brands: We may disclose personal information between and among MNAI and its current and future parents, affiliates, subsidiaries, our brands, and other companies under common control or ownership.
- Business/Promotional partners: We may share limited information with third parties with whom we partner that sponsor or offer a rewards program or provide contests and sweepstakes, or other joint promotional activities or co-branded services.
- Online advertising partners: We also share personal information with advertising networks or permit these partners to collect information from you directly on our websites to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms.
- Service providers: We share personal information with third-party vendors, consultants and other service providers whom we engage to perform functions or services on our behalf and under our instructions in connection with the purposes and uses described in this Privacy Notice. Such service providers are under contractual obligations to maintain the confidentiality of your personal information and to use such information only pursuant to our instructions.
- Third parties at your request: We share your personal information with third parties with your consent or at your direction.
- Third parties in the context of a corporate transaction: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership, in compliance with applicable law.
- Law enforcement and third parties pursuant to legal request: From time to time, we may disclose personal information as reasonably necessary to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
We do not “sell” personal information as most people would typically understand that term. However, we do allow certain advertising networks, social media companies and other third-party businesses to collect and disclose your personal information directly from your browser or device through cookies and related technologies when you visit or interact with our websites or otherwise engage with us online. Please see the Third-Party Tracking and Online Advertising section below for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other services, and the choices you may have in relation to those practices.
3. Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
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The Right to Know |
You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity: · The specific pieces of personal information we have collected about you; · The categories of personal information we have collected about you; · The categories of sources of the personal information we have collected about you; · The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; · The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and · The business or commercial purposes for collecting or, if applicable, selling personal information about you. |
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The Right to Request Deletion |
You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions. |
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The Right to Opt Out |
You have the right to direct us not to sell personal information we have collected about you to third parties.
If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales. |
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The Right to Non-Discrimination |
You have the right not to receive discriminatory treatment for exercising any of the rights described above.
However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner. |
4. How to Exercise Your California Privacy Rights
Please note that when you submit a request to us to exercise your rights as outlined in the instructions below, that request will only be submitted to the BFGoodrich Brand.
To Exercise Your Right to Know or Right to Deletion
To exercise your right to know and/or right to deletion with BFGoodrich, please submit a request by:
· Filling out our Consumer Rights Request Form, or
· Calling 1-888-971-3804.
We will need to verify your identity 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. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion to that personal information identified on the Consumer Rights Request Form, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.
To Exercise Your Right to Opt Out of Personal Information Sales
As noted above, we do not “sell” personal information as most people think of that term. You may, however, exercise your right to opt out of any future potential sales by clicking the link below and following the instructions:
Do Not Sell My Personal Information
You do not need to create an account with us to exercise your Right to Opt Out of Personal Information Sales. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal information 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.
Once you make an opt-out request, you may change your mind and opt back into personal information sales at any time by contacting us at Privacy.AMN@michelin.com
Third-Party Tracking and Online Advertising
We utilize third-party partners to engage in online advertising. These ad networks, social media companies and other third-party businesses collect your personal information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our websites, or otherwise engage with us online. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage, Geolocation Data, and Inferences generated from your browsing history and interactions with our Services as well as other sites and services. These third-party businesses use your personal information to serve relevant ads on our websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third parties may use such personal information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks.
By visiting www.privacyrights.info or www.optout.privacyrights.info, you can opt out from sales of this type of personal information by businesses that participate in the opt out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices. Please see our Privacy Notice and Cookie Notice or more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those practices.
Minors Under Age 16
Beginning in 2021 we will provide annual statistics about the requests to exercise California privacy rights we receive, fulfill and deny.
5. Updates to These California Disclosures
We will update these California Disclosures from time to time. When we make changes to these California Disclosures, we will change the "Last Updated" date at the beginning of these California Disclosures. If we make material changes to these California Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
6. Contact Us
If you have any
questions or requests in connection with this Notice or other privacy-related
matters, please send an email to Privacy.AMN@michelin.com.
Alternatively, inquiries may be addressed to:
Michelin Privacy Officer
One Parkway South
Greenville, SC 29615