PRIVACY POLICY

AWARENESS DECLARATION ON PERSONAL DATA PROCESSING

 

Summary

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 and awareness declaration on data processing is prepared based on Article 10 of the Law on the Protection of Personal Data No. 6698 (“the Law”) published in the Official Gazette dated 07.04.2016 and numbered 29677 and 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.

With this respect, Michelin will be processing, recording, storing, classifying, updating your personal data correctly and updated in accordance with the laws and good faith in connection with, limited to and in proportionate with the purposes mentioned below and be disclosing/transferring to the third parties in cases permitted by legislation and/or limited to their processing purposes.

If you are a resident of the United States, please click here for Us-specific privacy disclosures.

If you are a resident of Canada, please click here for Canada-specific privacy disclosures.

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

  1. Who we are and how we can be contacted
  2. Our websites covered by this privacy policy
  3. About our Privacy Department
  4. Other policies you should read
  5. Information we may collect from you
  6. Information we may collect from your Online Account Guide Michelin
  7. Information we collect about you from other places
  8. Where we store your personal information
  9. Sharing your personal information
  10. International transfers
  11. How long will personal information be kept by us
  12. Your rights under data protection legislation
  13. What you can do if you’re not happy with how we use your information
  14. About Data Security
  15. Changes to our Privacy Policy

 

  1. Who we are and how we can be contacted

Our full company name is Manufacture Française des Pneumatiques Michelin (“Michelin”), a subsidiary of the Michelin Group 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:

  • email us at Contact us by specifying the subject of your request and the Michelin service concerned (example: Restaurant or Hotel selection)
  • You can send us a letter addressed to the Privacy Department: 27, cours de l’Ile Seguin, 92105 Boulogne-Billancourt Cedex,
  • You can also contact us using our contact form on our website here
  • You can also contact us by telephone on +33 (0)1 55 19 57 00/01

When you submit a request, please describe your request with sufficient detail that allows Michelin to properly understand, evaluate, and respond to it.


  1. Our websites covered by this privacy policy

The information set out in this policy is applicable to the following websites:

  • Guide MICHELIN
    • website available here and through the local extensions accessible from the home page
    • mobile application available on market mobile applications stores

    1. About our Privacy Department

    While everyone at Michelin is committed to protecting and respecting your privacy, we have a data protection Privacy Department who deals with all aspect of personal data at Michelin. You can contact our Privacy Department by sending a message on Contact us

    1. Other policies and information we encourage you to read

    While this Privacy Policy contains all the information you need on how we collect and use your personal information on our websites, there is information in some other places which we encourage you to read.

    • Additional privacy policies
    • Our Cookie Policy
    • Our Terms of Website Use
    • Linked Platforms

    • Additional privacy policies

    This is our main privacy policy for your use of website and digital services and products offered by Michelin. However, there may be additional information in privacy policy for specific digital products and services. Please read these policies when you register or subscribe to these products and services.

    • Our Cookie Policy

    When you use our website and other digital products and services provided by us, information can be collected through cookies to distinguish you from other users of our website and other digital products and services. We have a separate Cookie Policy which explains our use of cookies and the purposes for which we use them. We encourage you to read our Cookie Policy here

    • Terms of use

    Our Terms of Website Use tells you the terms on which you may make use of our websites and should be read alongside this Privacy Policy and Awareness Declaration. You can read our Terms of Website Use here

    • Linked platforms

    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.

    1. Information we may collect from you

    This section sets out:

    • how we collect your personal information collection method;
    • 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
    • Whether or not the data is transferred out of Turkey; and
    • Your rights as data subjects

     

    We may collect and hold the following information about you:

    Data collected

    Purpose/Activity

    Type of Data

    Lawful basis for processing

    Retention period

    If you request further information from us or our partners by signing up to receive any newsletters or marketing communications

    (“Marketing Data”)

     

    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 email address and  your country location  so we can send you these information.

    The legal basis for this processing is your consent.

     

    Michelin will not keep Marketing Data more than 3 years after our last contact.

    Information you provide to us when you complete a survey or respond to a questionnaire or submit a review or feedback of a restaurant

    (“ Review Data”).

    To collect information about a specific matter, for example, our services to you or reviews of a restaurant you have visited.

    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.

    Information may include your full name, your email address and other personal data requested.

    We will use our legitimate interests in the monitoring and improvement of our products and services to our customers and users as the legal basis for processing Review Data.

    While we like to retain reviews and feedback from you to help other diners, we will anonymise or delete your reviews and feedback after 5 years.

    Any information collected pursuant to a survey or questionnaire will be deleted within 3 years of you submitting your responses. Any information retained will be aggregated, statistical data only.

    Information you provide us when you communicate with us, e.g. by email or contact us form via 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 the 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. Once your matter has been dealt with, unless we inform you otherwise, we will delete Communication Data within 3 years.

     

    Voluntary Information

    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.

    Statistical Information

    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 others 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 18, 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 18) has provided their personal information to us, without your consent, please let us know as soon as possible by emailing Contact us so that we can take appropriate action.

     

    1. Information we collect about you from your Michelin Guide Account

     

    Michelin, an expert in recommending restaurants and accommodation, and its subsidiary Tablet, which specializes in listing boutique hotels and upscale establishments, are combining their expertise to offer a joint selection through the joint Michelin Guide account. The Michelin Guide application and website gives you the possibility to create a user account to manage your favorites and reservations.

    This novel approach is designed to enable our users looking for unique experiences to quickly find and reserve both a restaurant and a hotel from a list of unusual addresses.

    Insofar as Michelin and Tablet jointly define the means and methods of collecting Personal Data related to the Michelin Guide Account, they are therefore jointly responsible for processing in accordance with data protection regulations. As such, the data collected via the Michelin Guide Account will be processed by each for all or part of the purposes specified below.

     

    Data collected

    Purpose/Activity

    Type of Data

    Lawful basis for processing

    Retention period

    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

    (“Account Data”).

    Account Data will be processed for the purpose of operating our websites, providing digital services you sign up for, communicating with you about those digital products and services and maintaining back-ups of our services.

    Account Data will include your profile information such as username and password that you may set to establish an online account with us, your photograph, personal bio, your interests, your favorites restaurants, hotels.

    The performance of the agreement between you and us for the provision of the digital product 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. If you do not access your account for 2 years, we will delete your account data so that we do not keep information for longer than is necessary. You can of course, create a new account if you like.

     

    Information you give to us when you book a restaurant

    (“Booking Data for Restaurant”)

    This information is used to enable us to provide you with restaurant booking services and complete your booking with the Restaurant.

    We also use this information to show you your past restaurant reservations and cancellations.

    We process personal information to facilitate your hotel booking  including by providing your name, payment card information and other reservation details or special request to the hotel where you book your stay

     

    The legal basis for this processing is to fulfil the agreement between you and Michelin MTP or the booking partner in relation to your booking.

    We retain your booking information for 3 years following your last dining experience. If you provide us with new information, we will update your details.

    Information you give to us when you book a restaurant

    (“Booking Data for Hotel”)

     

    For more information, please refer to the Tablet Privacy Policy [Tablet Privacy Policy]

     

    This information is used to enable Tablet to provide you with Hotel booking services and complete your booking with the Hotel.

    We also use this information to show you your past Hotel reservations and cancellations.

    We process personal information to facilitate your hotel booking including by providing your name, payment card information and other reservation details to the hotel where you book your stay.

    The legal basis for this processing is for Tablet, as data processor, to fulfil the agreement between you and the hotel.

    We retain your booking information for 3 years following your last dining experience. If you provide us with new information, we will update your details.

     

     

    1. Information we collect about you from other places

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

     

    Data collected

    Purpose/Activity

    Type of Data

    Lawful basis for processing

    Retention period

    We may collect your location data (“Location Data”).

     

    This data is used by us to provide our location-based services (research of nearby restaurant)

     

    IP Address

    Information from the GPS functionality of your mobile device

    The legal basis for this processing is your consent.

    No retention

     

    We may collect information from our web servers’ logs (“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.

    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.

     

    Information may include your connexion log,  IP address, operating system and browser type, language preferences.

    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.

    The legal basis for this processing is our legitimate interests, namely monitoring, improving our website, products and services and growing our business.

     

    1 year

    We and our business partners collect information using cookies or other similar technologies stored on your device (“Behavioural Data”)

    This information is used to analyse how you use our website, digital products and services. They help us to improve our websites, deliver a better and more personalised service to you, display relevant advertising.

    We may match your Behavioural Data with your Marketing Data to send you personalized notifications and/or newsletters. To reach this purpose we and our authorized partner can use technologies on our websites or digital service such as Data Management platform (DMP).

     

     

    Cookies contain information that is transferred to your computer's hard drive. Information may include your display and search preferences, your search history, your location, the way you are surfing on /using our websites, products or newsletters such as mouse move, display duration and clicks) and your interests.

    The legal basis for this processing is your consent or, where relevant, our legitimate interests, namely monitoring and improving our website, products and services and offer you personalized content or newsletters.

     

    Michelin will not keep this Data more than 13 month after the collect

     

    1. Marketing Communications

    You may 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.

    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

    • by clicking on the unsubscribe option or preference center at the bottom of each marketing communication we send to you; and
    • 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.

    Marketing from Restaurants and Partner Networks

    When you book a Restaurant, you may also have the option to opt-in for marketing communications from that Restaurant or Partner. We will always ask you for your express consent before allowing Restaurants or Partner Networks to market to you. Restaurants and Partner will have access to information on which individuals have opted-in and which have chosen not to opt-in.

    Marketing by the Restaurants and Partner are subject to their own privacy policies and you should consult these privacy policies for further information.


    1. Where we store your personal information

    In practice, the personal data you provide to us by signing to receive our newsletters, marketing communications or booking data are hosted in the European Union or United States therefore transmitted out of Turkey based on your explicit consent

    • For Marketing Data by our subcontractor Sales Force (or other subcontractor) and technical support is provided from the United States and therefore your personal data can be accessed from the United States. This transfer is governed by a contract containing the clauses of the European Commission as mentioned above.
    • For Restaurant Booking data by our Booking Partner such as LaFourchette SAS (TheFork) or any other Booking Partner, information is stored on secure servers within UK or EEA.
    • For Online account data by Tablet Inc: information is stored on secure servers within United States.

    1. 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 outside Turkey based on your explicit consent to the extent necessary for the same purposes of the initial processing set out in this policy and awareness declaration.

     

    • Service Providers - Michelin may share your personal data with subcontractors that Michelin may use to process your request or provide the services. These subcontractors act as data processors on our behalf and provide IT and system administration services, such as hosting and email and SMS services.

     

    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

    Third parties can collect information about you on our website, products or services via cookies or similar technologies, in order for example to provide personalised ads or to make profiling. These cookies will be accepted by you in accordance with our Cookie Policy. You can read it here.here .

    If you consented to receive offers from our partners, we can also transfer your Marketing Data to third parties, in order to send you newsletters and marketing communications as mentioned above (section 7).

    • To the restaurants

    Michelin share Booking Data, reviews, where applicable payment data and other relevant information you provide us with the Restaurants that you request services from. This information is provided to the Restaurants to enable them to continue to process and manage your booking regarding their role as Data Controller one Michelin pass your information to the Restaurant.


    1. 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 based on your explicit consent

    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.


    1. 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 5 and 6 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.


    1. Your rights under data protection legislation

    . Data protection legislation provides you with certain rights, depending on your applicable law, when it comes to the processing of your information.

    You have the right to learn whether your personal data has been processed or not; to request information about it, if it has been processed, to learn the purpose of processing and that if it has been used for its purpose, to learn if it has been transferred to third parties at home or abroad, to request notification of transactions made by third parties to which it has been transferred, to request correction of personal data if it has been processed imperfectly or wrong, to request deletion or destruction if the reasons for the processing have disappeared, to request notification of transactions made, to the third parties which it has been transferred, to object the result against you exclusively arose through the analysis made via automatic systems and request your loss to be indemnified in case you suffer a loss due to the processing in contrary to the Law, by applying to our Company


    1. 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 here ,
    • You can send us a letter addressed to the Privacy Department, 27, cours de l’Ile Seguin, 92105 Boulogne-Billancourt Cedex,

    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 your local supervisory authority website.


    1. About Data Security

    Michelin has implemented all operational and technical 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 by an authorized payment service provider 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.

    1. Changes to our Privacy Policy

    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 [May 2022]