Additional Canadian Privacy Disclosures
Last Updated: January 1, 2023
1. Scope of Rights
These additional Canadian Privacy Disclosures (the “Canadian Disclosures”) supplement the information contained in our Privacy Notice regarding the Michelin Brand websites, products and service offerings, mobile applications and services that post or link to these Privacy Disclosures (collectively, “Michelin”, “we”, “us”, or “our”) and apply solely to individual residents of Canada (“consumers” or “you”).
Unless otherwise expressly stated, all terms in these Canadian Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in PIPEDA.
2. Personal Data Disclosures
We collect various categories and types of personal data from a variety of sources and for a variety of purposes. We also disclose personal data to a number of recipients. Please review the ”Our Collection of Personal Data,” ”Our Use of Personal Data” and, ”Our Disclosure of Personal Data” sections of our Privacy Notice to learn more. We also disclose personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual’s activities across businesses or distinctly branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”).
We may at times receive, or process personal data to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.
3. Your Privacy Rights
Depending on your province of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
The Right to Know
The right to confirm whether we are processing personal data about you and to obtain certain personalized details about the personal data we have collected about you, including:
· The categories of personal data collected;
· The categories of sources of the personal data;
· The purposes for which the personal data were collected;
· The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom this personal data were disclosed;
· The categories of personal data shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for these purposes.
The Right to Access & Portability
The right to obtain access to the personal data we have collected about you.
The Right to Correction
The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.
The Right to Request Deletion
The right to request the deletion of personal data that we maintain about you, subject to certain exceptions.
The Right to Opt Out of Targeted Advertising
The right to direct us not to disclose personal data for certain targeted or cross-context behavioral advertising purposes.
4. How to Exercise Your Privacy Rights
Please note that when you submit a request to us to exercise your rights as outlined in the instructions below, your request will be Brand-specific.
To Exercise Your Privacy Rights
Please submit a request by:
We will need to verify your identity and confirm you are a resident of a Canada. 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. As a result, we require requests to include name, email address, and province of residency. Although we try to limit the personal data collected in connection with a request to exercise any of the above rights, certain requests may require us to obtain additional personal data from you. In certain circumstances, we may decline a request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible jurisdictions.
To Exercise the Right to Opt Out of Targeted Advertising
Unless you have exercised your Right to Opt Out, we may disclose your personal data to third parties for targeted or cross-context behavioral advertising purposes. These third parties may use such information for their own purposes in accordance with their own privacy statements, which may include reselling or disclosing this information to additional third parties.
You do not need to create an account with us to exercise your Right to Opt Out. However, we may ask you to provide additional personal data so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal data 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 at any time by returning to the “Your Privacy Choices” link or contacting us at Privacy.AMN@michelin.com.
In certain circumstances, you may be permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your province of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
5. Data Retention
We retain personal data only for as long as is reasonably necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator, or other government authority.
To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations. Therefore, we retain personal data for as long as the individual continues to use our services for the purposes explained in the Our Use of Personal Data section in our Privacy Notice. When an individual discontinues the use of our services, we will retain their personal data for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices they have made, such as to receive marketing communications. In particular, we will retain call recordings, the personal data supplied when joining our services, including complaints, claims (for insurance products) and any other personal data supplied during the duration of an individual’s contract with us for the services until the statutory limitation periods have expired, when this is necessary for the establishment, exercise, or defense of legal claims.
Once retention of the personal data is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal data and isolate it from further processing until deletion or deidentification is possible.
6. Data Security
We use physical, technical, and administrative security measures designed to mitigate the potential for the unauthorized access, use, communication/disclosure, or alteration of your personal data. However, no system of security measures can guarantee the security of the personal data we collect. In addition, you have a shared responsibility to keep your personal data secure when you use our websites, mobile apps, and web applications. Please take the following steps to help secure your personal data: (i) install the latest security updates and anti-virus software on your device to help prevent malware and viruses; (ii) use the latest version of browsers (iii) if you have an online account with us, change your account password frequently; (iv) use complex passwords to lock your device and mobile applications; (v) do not use the same password for online accounts with us that you use elsewhere; and (vi) do not share your password with others.
7. Updates to These Canadian Privacy Disclosures
We may change these Canadian Disclosures from time to time. Any changes we make to this notice in the future will be posted on this page. All changes shall be effective from the date of publication unless otherwise provided.
8. 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:
North American Privacy Officer
Michelin North America, Inc.
One Parkway South
Greenville, SC 29615