PRIVACY POLICY

Michelin makes every effort to protect your personal data and to present, in a clear and transparent way, the information about the way in which your personal data is collected and used. This privacy policy explains how any personal information collected when you use our website or digital services, or provided to us, is processed.Please read the following policy carefully to understand Michelin’s attitude and practices regarding personal information and the way we use it.1. Who we are and how to contact us2. Michelin’s websites governed by this privacy policy3. About our Data Protection Officer4. Other policies you should read5. Information we may collect from you6. Marketing Communication7. Information we collect about you from other sources8. Personal data storage9. Sharing personal data10. International transfers of personal data11. Personal data storage duration12. Rights of personal data entities resulting from data protection acts13. Procedure for enforcement of rights regarding personal data14. Data Security15. Changes to Michelin’s privacy policy

1. WHO WE ARE AND HOW TO CONTACT USThe full company name is Michelin Polska S.A. with the seat in Olsztyn in Leonharda 9 St., 10-454 Olsztyn, Poland, listed in the commercial register in the Regional Court in Olsztyn, VIII Commercial Division of the National Court Register number: 0000163137, Share capital: 979.920.576,00 PLN fully paid-up, Tax ID: 739-020-38-25, Regon: 510008834 (hereinafter referred to as „Michelin”). Michelin is direct data administrator for users visiting its website and using Michelin’s services. You can contact Michelin via:e-mail: kontakt_iodo@michelin.com;mail sent to the address: Michelin Polska S.A., ul. Leonharda 9, 10-454 Olsztyn (with a note: „Data Protection Officer”);telephone: +48 89 532 33 15

2. MICHELIN’S WEBSITES GOVERNED BY THIS PRIVACY POLICYInformation provided in this document applies to the websites on which this privacy policy is published.

3. ABOUT OUR DATA PRIVACY OFFICERAll Michelin’s employees are committed to protecting and respecting your privacy. Moreover, our Data Privacy Officer, Mrs Zofia Ramus, supervises all the aspects of personal data in Michelin. You can contact her by sending an e-mail to: kontakt_iodo@michelin.com

4. OTHER POLICIES YOU SHOULD READEven though this document contains all the information concerning the way of collecting and using your personal data on Michelin’s website, we would like to encourage you to read the information published elsewhere.Additional privacy policies, cookie policy, connected platforms

Additional privacy policiesThis document presents Michelin’s main privacy policy concerning using the websites, digital services and products offered by Michelin. However, the privacy policy concerning specific products and digital services may contain additional information. Please read this information when registering or subscribing to these products and services. 

Cookie PolicyWhile using our website or other digital products and services provided by Michelin, additional information may be collected by cookies to identify the users of the websites or digital services and products provided by Michelin. We have a separate cookie policy that explains the use of cookies and the purpose of using them by Michelin. We encourage you to read our cookie policy here: https://praca.michelin.pl/pl/cookies-policy_poland

Connected platformsMichelin’s website may contain hypertext links to and from our websites and digital platforms of our partner networks, advertisers, affiliated entities and social networking sites. If you click a link to any of these websites, please note that they have their own privacy policies and Michelin accepts no responsibility with regard to these policies. Check these policies before sending any personal information to these websites.

This section presents:the way we collect your personal informationthe categories of data that we collectthe way we use the information we collectthe legal basis for processing the collected informationthe storage duration of the collected informationMichelin may collect and store the following information about you:

Voluntary InformationWhen you provide us with information (eg. the information set out in the scenarios above), in some cases, Michelin may ask you for additional, voluntary information. This information, identified as optional, is used to help us better understand our customers and tailor our services to them.Statistical InformationMichelin also collects and uses 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, Michelin may aggregate data concerning the usage of the website and data from the device to calculate the percentage of our website users accessing specific features available on the website. The aggregated data is only used for our business purposes.Sensitive Personal InformationWhile we do not request sensitive personal data, we do have sections on our websites where you can submit additional information. When submitting an opinion, bear in mind that some of it may be sensitive information. Only submit the information you wish to disclose.Children and Personal InformationThis website is not designed for children and we do not knowingly collect data relating to children. If we become aware that we store 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 by sending us an e-mail: kontakt_iodo@michelin.com, so we can take the appropriate action.6. MARKETING COMMUNICATIONYou will receive Michelin’s marketing communication and newsletters only if you wish to receie them.Therefore, Michelin will, in most cases, only use your name and e-mail address.In each case, you can unsuscribe from newsletters or marketing communication at any time:by clicking the „unsubscribe” option, which can be found at the bottom of each marketing message.by contacting Michelin, sending an e-mail or a letter to the address provided in this document.We usually send marketing communication to our recipients until they resign from it. If we do not receive a message from you for a longer time or you do not open our e-mails for 3 years, your personal data will be deleted from Michelin’s database. You can renew your subscription at any time.Occasionally we might use data from your devices and data concerning the usage of our website, to provide you, via e-mail, with suggestions and recommendations regarding the products and the services that you might be interested in. It is necessary in terms of Michelin’s legitimate interest in the development of our products and services and the development of the company.

7. INFORMATION WE COLLECT ABOUT YOU FROM OTHER SOURCESTo 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 other websites we operate or other products and/or services we provide. We also work closely with third parties (including, for example, business partners, subcontractors in technical or payment services, analysts, search information providers and credit information agencies) and we may receive information about you from them. The legal basis for processing this data is our legitimate interest in monitoring and improving our website, products and services.Information from our web servers’ logs, for example, information about your computer, operating system, web browser or IP address. We may also collect information on the searches you carry out on our website and your interaction with the messages we send to you, for example, whether you have read a message sent by us. (“Usage and Device Data”). Michelin uses this kind of information for system administration and to analyse the way people use 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 interest regarding especially monitoring and improving our website, products and services.As mentioned above, we collect information about the way in which you use our website, use our cookies or other similar technological solutions stored on your device. Cookies, transferred to your computer’s hard drive, contain information that helps us to improve our websites and deliver a better, more personalised service to you. You can read our Cookie Policy here https://praca.michelin.pl/en/cookies-policy_poland.Our website is integrated with external social networks, such as Facebook, Twitter or Linkedin, in order to let you your experience and connect with us via these sites. We may collect the information from our social media sites, including likes, shares and tweets, and about the content presented on those networking sites. We do not control the privacy of the information you provide on social media networks, which apply their own privacy policies.

8. STORAGE OF YOUR PERSONAL DATAAll the information that is provided to us is stored on secure servers in the EEA territory.Despite our best efforts to keep your personal information secure, transmission of information via the internet is not completely secure. Together with our service providers, we do our best to protect your personal data but information provided is at the sole risk of the user.9. SHARING YOUR PERSONAL INFORMATIONWe only share your personal data with people who have a need to know such information to carry out their duties. 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 obliged to keep the personal information they may have received confidential and secure and to use your personal information strictly in accordance with our instructions.We may also share your personal information with third parties:For legal reasonsIf 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 consentThird parties can collect information about you on our website via products or services using cookies or similar technologies, in order for example to provide personalized ads or for user profiling. These cookies will be accepted by you in accordance with our Cookie Policy. You can read it here https://praca.michelin.pl/en/cookies-policy_poland.10. INTERNATIONAL TRANSFERS OF PERSONAL DATAMichelin is an international group with databases in 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 transfer 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 the European Economic Area. Binding corporate rules are available at: kontakt_iodo@michelin.com.Transfer of personal data outside the group is subject to either BCR of the subcontractor or contracts containing clauses of the European Commission for suppliers based outside the EU, to guarantee a similar level of protection as in the home country.11. PERSONAL DATA STORAGE DURATIONAs 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 refer to section 5 above.To determine the appropriate retention period for personal data, we consider the amount, the nature, and the 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 these purposes by other means and the applicable legal requirements.In some cases you can request that Michelin deletes your personal data. You will find the detailed information below.In some circumstances we may anonymize 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 informing you about that fact.12. YOUR RIGHTS UNDER DATA PROTECTION LEGISLATION.Data protection rights vary by jurisdiction. Michelin strives to comply with all data protection laws, and takes these requirements seriously. You may have certain rights by virtue of your residency or citizenship. It is recommended that you contact your local governmental organization to learn more.Data protection provisions provide certain rights regarding data processing. These are:The right to be informed about data collectionThe right to access your informationThe right to rectify your informationThe right to delete your informationThe right to limit processingThe right to transfer informationThe right to object to processingThe right to issue instructions after death.Further information regarding your rightsThe ight to be informedYou have the right to be informed about how we collect and process your personal data, who we are, how we use your personal data and your rights in relation to your personal data. You will find all the necessary information in this privacy notice.The right to access your informationYou have the right to access your personal data that we have collected. We can confirm whether your data is processed and provide you with access to these personal data.The right to rectify your informationIf your personal data is inaccurate or incomplete, you have the right to correct and update it. If we have disclosed your data to third parties, whenever possible, we will inform them of any modifications you have made. You can update the personal information we have about you by contacting us using any of the methods outlined in this Privacy Policy.The right to delete your informationYou have the right to request deletion or cancellation of your personal data if there is no reason for us to continue its processing. You can request exercising this right if the information is no longer needed in relation to the purpose for which it was originally collected or processed and if the consent for processing has been withdrawn.There are certain circumstances in which this right does not apply. Please contact us for more information.The right to limit processingYou also have the right to “block” or limit the processing of your personal data. We will stop further data processing on your request.The right to transfer informationIf you want to transfer your personal data to another service provider or copy the information for your own purposes, you have the right to request the transfer your data.The right to object to the processing of personal dataYou have the right to ask Michelin to discontinue processing your personal data for marketing purposes. Usually, the user is informed (before data collection) about the intention to use his/her data for such purposes or about the intention to disclose his/her data to any third-party for the same purposes. You can exercise your right to prevent such processing by marking the relevant boxes in the forms we use to collect your data.You can also exercise the right at any time by contacting us at: kontakt_iodo@michelin.com.Further information regarding personal data protectionFor more information contact Personal Data Protection Office at: https://uodo.gov.pl/.13. GRIEVANCE PROCEDUREWe are committed to protecting and respecting your privacy. However, if you are not satisfied with the way we collect or process your data or you require further information on your rights, you can contact us as in the following ways:Via e-mail: kontakt_iodo@michelin.comBy mail at: Michelin Polska S.A. ul. Leonharda 9, 10-454 Olsztyn (with a note: Data Protection Officer)We will cooperate with you to solve any issues you may have. We will also respond to any questions raised by you as soon as possible.You can also file a complaint with Personal Data Protection Office. Further information available at: https://uodo.gov.pl.14. ABOUT DATA SECURITYMichelin 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 and 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. This information will be used only for purposes of online payment and will not be retained.Michelin ensures that your personal data will not be altered, damaged or revealed to unauthorized third parties.15. CHANGES TO OUR PRIVACY POLICYWe may change our policy from time to time. Any changes we make to this policy in the future will be published on this page. If you have an online account with us, we may notify you of any changes by email or when you log onto your account. DATE: 16 October 2018