Michelin is committed to protecting your personal information and being clear and transparent about what information we collect and how we will use it. This policy explains how any personal information we collect when you use our website or digital services, or that you provide to us, will be processed by us.
Please read the following policy carefully to understand our views and practices regarding your personal information and how we will treat it.
- - Who we are and how we can be contacted
- - About our Data Protection Officer
- - Other policies you should read
- - Information we may collect from you
- - Marketing Communication
- - Information we collect about you from other places
- - Credit reporting policy
- - Where we store your personal information
- - Sharing your personal information
- - International transfers
- - How long will personal information be kept by us
- - Your rights under data protection legislation
- - What you can do if you’re not happy with how we use your information
- - About Data Security
1. Who we are and how we can be contacted
Our full company name is Michelin Australia Pty Ltd (“Michelin”) and when you use our website and our services directly, we act as a Data Controller.
If you need to contact us you have a number of options, you can contact:
- email us at firstname.lastname@example.org
- You can send us a letter addressed to Data Protection Officer 51 – 57 Fennell Street Port Melbourne VIC 3207
Michelin Australia (we or us) is committed to maintaining the privacy of our customers or persons visiting our website, https://www.michelin.com.au/ This page set out our policy on how we manage “personal information”. This policy also includes our “credit reporting policy” and how we manage information collected in connection with a credit application or a credit facility (hereinafter collectively referred to as credit information).
3. About our Data Protection Officer
While everyone at Michelin is committed to protecting and respecting your privacy, we have a Data Protection Officer who deals with all aspect of personal data at Michelin. You can contact our Data Protection Officer by sending an email to email@example.com
4. Other policies and information we encourage you to read
Additional privacy policies
- Our Terms of Website Use
- Linked Platforms
Additional privacy policies
Our site may contain links to and from our websites and digital platforms of our partner networks, advertisers, affiliates and social media pages. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
5. Information we may collect from you
This section sets out:
- how we collect your personal information;
- the categories of data that we collect;
- a description of how we plan to use the information we collect;
- the legal basis that we will rely on to process information collected;
- how long we will hold the information collected; and
- specific types of data
We may collect and hold the following information about you:
Type of Data
Lawful basis for processing
Information you give to us when you enter a competition or promotion (“Competition Data”).
To enable us to send you further information about the competition or a prize if you are the competition winner. Unless we state otherwise when we collect your information, we will only use this information for managing and administer the competitions or promotions.
Competition Data might include, for example, your name and e-mail address.
If you win a prize we may request your full address to enable us to send you your prize
The performance of an agreement between you and us to enter the competition or promotion.
If you are a competition participant, we will collect, maintain, disclose the information according to the terms and conditions of the competition or promotion and you will be able opt out or withdraw consent by following the instructions provided in the competition or promotion terms and conditions.
Information you provide to us when you complete a survey or respond to a questionnaire or submit a review or feedback (“Review Data”).
To collect information about a specific matter, for example, our services to you or reviews of our products/services.
In many cases surveys, and questionnaires are anonymous, and we only collect personal information for statistical data. If this is not the case, we will let you know at the time of collecting the information. If such functionality is available, feedback and reviews may be disclosed on the Website with some personal information. In such case, you will be informed.
Information may include your full name, your email address and other personal data requested.
As the legal basis for processing Review Data, we will use our legitimate interests in the monitoring and improvement of our products and services to our customers and users and in the sharing of customer experience with web users.
While we like to retain reviews and feedback from you to help other web users, we will anonymise or delete your reviews when you opt out or withdraw consent by following the instructions provided in the survey or questionnaire, or by exercising your right to delete your information as set out in clause 13, and by contacting us at details given in clause 14.
If you register for any of our digital products or services via an account we will request information to enable us to identify you and provide the products and services to you (for example, when you access the web based platform via the two step security system from your mobile to access SFDC (Salesforce Partner Portal) to respond to Customer complaints / enquiries we will request information to enable us to identify you and provide the services to you) (“Account Data”).
Account Data will be processed for the purpose of operating our Platforms, providing digital services you sign up for, communicating with you about those digital and services and maintaining back-ups of our services.
Account Data will include your full name, email address. We may also ask you to set a password so you can securely log on to your account.
The performance of the agreement between you and us for the provision of the digital and services is the legal basis for processing Account Data.
We will retain Account Data for as long as you have an account with us and insofar as it is required to be retained for an extended period of time (e.g. for tax or accounting purposes). If Account Data is not required to be retained for a specific purpose, we will delete your Account Data (i) if your account has been inactive for a prolonged period, (ii) if you request for your information to be deleted, (iii) or upon the closure of your account.
Information you provide us when using location services, for example our dealer locator (“Location Data”).
This information is used to identify dealers in that surrounding location.
The performance of the agreement between you and us for the provision of the digital product and services is the legal basis for processing Location Data.
We do not obtain any Location Data and therefore we do not keep them.
Information you provide us when you communicate with us, e.g. by email or contact us from via our Portal / websites or through the live chat function on our website . (“Communication Data”)
This information is used to enable us to respond to or following up on your comments, queries, or questions
· Information may include your full name, your email address, and other personal data you provide us to enable us to deal with your communication.
We will use our legitimate interests in assisting you and answering your communications as the legal basis for processing Communication Data.
We will hold on to Communication Data for as long as it is necessary to enable us to deal with the matter relating to that communication. We may retain reasonable records of Communication Data for an extended period of time as required for business, legal or audit purposes.
(For Salesforce or other Portal / websites, Data will be retained in accordance with the terms and conditions of sites policy.
If you request further information from us by signing up to receive any of our newsletters or marketing communications (“Marketing Data”). For further details, see section 6 below.
Marketing Data is processed for the purposes of sending you the relevant notifications and/or newsletters and/or any marketing communication.
· We will ask you for your name and email address so we can send you these information.
The legal basis for this processing is consent.
We will keep Marketing Data according to the terms and conditions mentioned in our newsletters or marketing communications and you will be able to opt out or withdraw consent by exercising your right to delete your information as set out in clause 13, by contacting us at details given in clause 14.
When you provide us information (for example, the information set out in the scenarios above), in some cases we may ask you for additional, voluntary information. This information will be identified as optional and is used to help us better understand our customers and tailor our services to them.
We also collect and use aggregated data such as statistical or demographic data (“Aggregated Data”). Aggregated Data may be derived from your personal information but does not reveal your identity in any way. 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. Aggregated Data is used for our own business purposes only.
Sensitive Personal Information
While 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 on these free text section, only submit information you are comfortable providing and always bear in mind that it may be sensitive information. If you submit reviews or feedback for our website, please remember that this information will be visible to other users of our website.
Children and Personal Information
This website is not intended for use by children and we do not knowingly collect data relating to children. If we become aware that we are holding any information about children under the age of 15, we will take any actions necessary to comply with data protection legislation, including if appropriate, deleting the information. If you become aware that your child (under 15) has provided their personal information to us, without your consent, please let us know as soon as possible via our contact form so that we can take appropriate action.
6. Marketing Communications
You will receive marketing communications or newsletters from us only (i) if you wish it, (ii) if you are one of our customers, provided that this communication will concern similar products or services or if (iii) this communication is linked to your business activity.
In this context, we will use the information you provide us, usually just your name and email address.
In any case, you can unsubscribe or make stop direct marketing from us at any time either
(i) by clicking on the unsubscribe option at the bottom of each marketing communication we send to you; and
(ii) by contacting us by email or letter using any of the contact details set out in this notice.
We will generally send you marketing communications until you choose to unsubscribe from receiving them. However, if we have not heard from you for a while or notice that you have not opened our emails in a period of 3 years, we will remove your details from our database. There’s nothing stopping you for subscribing again at any time.
From time to time we may also use your Usage and Device Data to make online suggestions and recommendations to you about goods or services that may be of interest to you. This is necessary for the legitimate interest of our business in developing our products and services and growing our business.
7. Information we collect about you from other places
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 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, sub-contractors in technical, payment services, analytics providers, search information providers and credit reference agencies – see section 8, Credit reporting policy, for more detail) and may receive information about you from them. The legal basis for his processing is our legitimate interests, namely monitoring and improving our website, products and services.
- Information from our web servers’ logs, for example information about your computer, such as your IP address, operating system and browser type. We may also collect information on the searches you carry out on our website and your interaction with communications we send you, for example, when you open email communications. (“Usage and Device Data”). This information is used by us for system administration and to analyse how people are using our websites and digital platforms. It also helps us to provide the best online infrastructure for your online activities. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website, products and services.
- Our website may enable you to share your experience and connect with us through third party social networks such as Facebook and Twitter. We may collect this information from our social media sites, including likes, shares and tweets, and about the content on social networking sites. We do not control the privacy of the information you provide on social media networks and the privacy policies of those social media networks will apply when using their services.
8. Credit reporting policy
What types of credit information do we collect and hold?
When you make a request to buy our products on credit, we may check your credit worthiness and at other times we may collect information about you from and give information about you to Credit Reporting Bodies (CRBs). This information may include:
- Your current and prior names and addresses, date of birth; ABN number; gender
- That you have applied for commercial credit (including the name of each relevant credit provider), the type and amount of that credit and the fact we have accessed your consumer credit information to assess a relevant application;
- That we and other credit providers are or have been a provider of credit to you and the type, certain terms that relate to repayment and maximum amount of credit that we have provided or will provide.
- The date that any credit contract we or other credit providers have or had with you was entered into and the date that it is terminated or otherwise ceases;
- Your repayment history i.e. whether in relation to credit facilities provided by us or other credit providers;
- Court proceedings information, personal insolvency information and credit-related publicly available information;
- Payments owed to us or another credit provider, in connection with credit provided to you or in relation to which you are a guarantor);
Whether in our or another credit provider's opinion you have committed a serious credit infringement;
- Whether you have entered into arrangements with us or other credit providers in connection with credit provided to you; Our evaluations relating to your credit worthiness are derived by us or by CRBs wholly or partly on the basis of the information above.
We gather credit information from your application and may also gather credit information from CRBs; other credit providers; co-applicants; guarantors/proposed guarantors; other references given by you; organizations that check the security you are offering such as valuers; organizations that issue identification documents regarding your identity; and our service providers involved in helping us to provide credit, including debt collectors and legal advisers.
Purposes for which we may collect, use and disclose your credit information
- Forming decisions on whether to provide you, or an entity associated with you, with credit or to accept you as a guarantor;
- Participating in the credit reporting system and providing information to CRBs in accordance with the Privacy Act and the Credit Reporting Code;
- Informing you in on your credit-related obligations and assisting you in avoiding a default;
- Undertaking debt recovery and security enforcement including in relation to guarantors
- Dealing with complaints and assisting other credit providers to do the same;
- Meeting legal and regulatory requirements. Disclosure of personal information to third parties
We may disclose your credit information to Credit Reporting Body (CRB) for purposes such as those described above where the Privacy Act permits us to do so or where required or authorized by law.
Michelin Australia deals with, and will likely disclose your credit-related personal information to, the following CRB: EQUIFAX AUSTRALIA INFORMATION SERVICES AND SOLUTIONS LIMITED (ABN 26 000 602 862) having its registered office at Level 15, 100 Arthur Street, North Sydney 2060 in the State of New South Wales (“Equifax”) http://www.equifax.com.au/credit-reporting-policy
Equifax may include the credit-related personal information we disclose to it in reports it provides to other credit providers to assist them to assess your credit worthiness.
You can obtain a copy of Equifax’s policy about its management of credit-related personal information from its website, as shown above.
Under the Privacy Act and as set out in our Credit Reporting Policy, you have the right to access the credit-related personal information we hold about you, to request that we correct that information and to make a complaint to us.
You have the right to request that a CRB not to use your credit reporting information for the purposes of pre-screening of direct marketing by a credit provider; and
You have the right to request that a CRB not use or disclose credit reporting information about you, if you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud.
We receive services from other Michelin Group companies and external service providers, some of which may be located outside of Australia (see the additional section below titled "International Transfers of Personal Data"), and your information may be provided to them for this purpose.
9. Where we store your personal information
All information you provide to us is stored on secure servers within EEA.
While we are committed to keeping your personal information secure, the transmission of information online via the internet is not completely secure. We, together with our service providers will do our best to protect your personal information but information provided is at your sole risk.
10. Sharing your personal information
We only share your personal data with people who have a need to know such information to perform their responsibilities. We may share your personal information with the following:
- Within the Michelin Group - we may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries to the extent necessary for the same purposes of the initial processing set out in this policy.
- Service Providers - Michelin may share your personal information with selected service providers that Michelin may use to process your request or provide its services to you. These service providers act as data processors on our behalf and provide IT and system administration services, such as hosting and email services and managing the ratings and reviews.
These service providers are legally obligated to keep the personal information they may have received confidential and secure and to use your personal information the basis of our instructions only.
We may also share your personal information with third parties:
- For legal reasons
If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of the Michelin Group, our customers, or others. In this context, we may disclose your personal information to our professional advisors who are under a duty of confidentiality.
- On the basis of your consent
11. International Transfers of Personal Data
Michelin is an international group with databases in the various countries in which it operates. Michelin may transfer your personal data within the group to one of its databases or to its external partners located outside of your home country.
As levels of data protection vary worldwide, we do not transmit your personal data to Michelin group companies or to third-party companies outside of the European Union unless these companies offer the same or similar level of personal data protection as Michelin.
For transfers within Michelin, the company has adopted internal rules governing the transfer of personal data from the European Union or European Economic Area.
Transfers of data outside the group are governed either by the BCR of the subcontractor or by contracts containing the clauses of the European Commission for suppliers established outside the EU to guarantee a similar level of protection as that of your home country.
12. How long will personal information be kept by us?
As a rule, we will not hold your personal information for any purpose or purposes for longer than is necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. For more specific retention periods, please see section 4 above.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see your right to be deleted below for further 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 which case we may use this information indefinitely without further notice to you.
13. Your rights under data protection legislation
Data protection legislation provides you with certain rights when it comes to the processing of your information. These are the right to:
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 object to processing
For further 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 gathered all the information you need in this privacy notice.
The right of access your information
You have the right to access the personal information we have on you. We can confirm whether or not your information is being processed and provide you with access to your personal information.
The right to correct your information
The right to delete your information
You have the right to request the deletion or removal of your personal information where there is no reason for us to continue to process it. The circumstances in which you can request the right to be forgotten includes, where the information is no longer necessary in relation to the purpose for which it was originally collected or processed and where you have withdrawn your consent to processing. See contact details in clause 14.
There is some limited circumstance where the right to be forgotten does not apply – if you want to know, just ask.
The right to restrict processing
You also have the right to ‘block’ or suppress the processing of your personal information. If you request us to suppress your personal information, we will stop any further processing of it.
The right to object
You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting 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 the right at any time by contacting us at firstname.lastname@example.org
For further information on your rights
You can find further information on your data protection rights from the Office of the Australian Information Commissioner at https://www.oaic.gov.au/privacy/privacy-complaints/
14. What can you do if you’re not happy
We are committed to protecting and respecting your privacy. However, if you’re not happy with how we collect or process your information or just want some further information on your rights, you can contact us in the following ways:
- You can email us at email@example.com
- You can send us a letter addressed to The Privacy Officer 51 – 57 Fennell Street Port Melbourne VIC 3207
We will work with you to resolve any issues you may have and aim to answer any question raised by you as soon as possible.
You can also make a complaint to Office of the Australian Information Commissioner – further information can be found at https://www.oaic.gov.au/privacy/privacy-complaints/
15. About Data Security
Michelin has implemented measures to protect the privacy, security and integrity of your personal data. Access to personal data is restricted to those employees and service providers who need to know this information and who have been trained to comply with rules on confidentiality.
On Michelin's commercial sites, banking information will be collected for the purposes of effective, legal secure payment processes. These measures may consist of SSL encryption (intended to make the data unreadable to others) during the collection or transfer of confidential data. Said information will be used only for purposes of online payment and will not be retained.
Michelin ensures that your personal data are not altered, damaged or accessed by unauthorised third parties.
We may change our policy from time to time. Any changes we make to this policy in the future 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 on.
Date: Nov 2021