We thank you for your interest in Truckfly by Michelin and its services.

This Personal Data Protection Policy (the "Policy") details the policy of the Manufacture Française des Pneumatiques Michelin (hereinafter "we" or "Michelin") regarding the collection, use and disclosure of information about you. (the "Personal Data"), in connection with the use of our Truckfly service, including our truckfly.com website and the Truckfly mobile application (collectively, the "Service"), and its use of cookies.

The Policy is intended to enable you to make informed decisions about the use of the Services. We therefore invite you to read it prior to using our Services and to each update.

1. WHO WE ARE AND HOW WE CAN BE CONTACTED?

2. INFORMATION WE MAY COLLECT FROM YOU

3. WHY AND HOW WE PROCESS YOUR DATA

4. DISCLOSURE AND CROSS6 BORDER DATA TRANSFERS

5. CONTROL TO YOUR PERSONAL DATA

6. Storage of your Personal Data

7. MINOR

8. ABOUT DATA SECURITY

9. YOUR PRIVACY RIGHTS

10. COOKIES

11. CONTACT

12. CHANGES TO OUR PRIVACY POLICY

1.Who are we ?

Truckfly services are proposed by Manufacture Française des Pneumatiques Michelin (“Michelin”) and when you use our website and our mobiles application we act as a Data Controller.

If you need to contact us you have a number of options, you can:

• email us at [email protected].

• send us a letter addressed to Place des Carmes Déchaux 63040 Clermont-Ferrand Cedex 9 France

• contact us by phone at +33 473 32 20 00

2. The Personal Data we collect

When you use the Service, we collect:

A - Account data: If you create an account on the Application, we may store and use your full name, age, email and telephone number. Your first name and the initial of your last name, as well as the photos you submit during registration, will be made public as part of your account profile. If you think that an unauthorized account has been created to represent you, or which resembles your profile, you can ask for it to be deleted by contacting us.

B - Your assessments, comments, favorites, "likes", changes to and additions of locations, account profile.

C - The list of your contacts: You can invite your friends to join the Service by allowing us to have access to your contacts from your mobile device or from third-party sites, in order to select the friends you wish to invite.

D - Marketing data: If you inform us that you would like to obtain additional information by subscribing to one of our newsletters or commercial messages, the marketing data will be processed in order to send you the relevant messages and/or newsletters, in line with your wishes. We will ask you for your last name, email and/or telephone number in order to send you the requested messages/newsletters. We will only send you messages/newsletters if you have given us your consent to do so, or when this is permitted by law, unless you specifically object. You can manage your communication preferences in the Application settings section.

We may track your actions in response to the messages you receive from Michelin or through the Service, notably when you delete, open or forward such messages.

However, please note that you cannot refuse to receive certain administrative or legal notifications from Michelin.

E - Company data: If you are the representative of a company listed on the Application, we may contact you, including by telephone or email, by using the contact information you provided us with (which is presumed to be for professional purposes) or that you have made publicly available, or by using the information we have registered for your company.

F - Contact data: If you decide to contact us, we may record the data you provide in your message.

G - Activity and geolocation: We may store data concerning your use of the Service, such as the searches you make, the pages you visit, the date and time of the visit, as well as the companies you contact using our Application. We may also store data concerning your use of the Service collected from your computer or mobile device, such as your browser type, type of computer or mobile device, browser language, your IP address, mobile operator, unique device identifier, your geographic location (including through geolocation, beacons and GPS location), as well as the requested and referring URLs. You may object to our use of certain location data in the "Privacy" section of the Application or via your mobile device or browser settings, notably by disabling the "Location Services" for the Application in your device's privacy settings, for example.

Some of this information is required in order to identify you when you create your account. If you do not provide this required information, your user account cannot be created. Required information will be indicated as such in the forms.

3.How we use your Personal Data and for what purposes

We use your Personal Data for specific purposes, each of which has a legal basis, as detailed below:

Purposes of the processing	Legal basis
To provide you with the Service and ensure it operates correctly,	The Service is provided on the basis of our General Terms and Conditions of Use, which you accept by subscribing to the Service. We therefore need to process your Personal Data in order to fulfil our obligations within the framework of this contractual relationship. Certain features of the Service require the use of geolocation, which is based on obtaining your prior consent.
To improve the quality of the Service, market and develop it,	We have a legitimate interest in providing you with the best possible Service and in developing our activities.
To track your use of the Service and personalize your experience,	We have a legitimate interest in providing you with the best possible Service and in seeking to meet your expectations and needs more closely.
To conduct surveys or polls	We have a legitimate interest in monitoring and improving the products and services provided to customers and users by Michelin or its partners.
To answer your requests and respond in an appropriate manner,	We have a legitimate interest in responding to your needs and requests.
To communicate with you in order to conduct marketing operations,	The use of your Personal Data for prospecting purposes is based on our legitimate interest in developing our relationship with you. We will only send you messages/newsletters if you have given us your consent to do so, or when this is permitted by law, unless you specifically object.
Customer support,	We have a legitimate interest in providing you with support when you explicitly request it.
To guarantee and improve the security of the Service, notably by backing up our systems and making it possible to recover data in the event of an incident or emergency,	We have a legitimate interest in protecting the security of our assets and Service.
To protect our rights and assets, as well as those of other users of the Service,	We have a legitimate interest in protecting our rights and ensuring the security of our assets and Service, as well as that of our users.
To comply with our legal obligations, with a court ruling or the requirements of legal proceedings, and the requirements of the regulatory authorities.	We may use your Personal Data within the framework a commercial transaction, to defend our rights in court, or to protect the rights of third parties, if this is based on our or a third party's legitimate interest. As regards the other purposes described in this section, we are obliged to use your Personal Data to comply with our own legal obligations.

4. Communication and transfer of your Personal Data

As part of the Service, we may share your Personal Data with the following categories of third parties:

Third parties to whom we outsource certain services, notably including, IT service providers or publishers, and IT support providers;

• Third-party providers who assist us with customer data analysis, for example, Google Analytics and Flurry;

• Third-party private messaging service providers who help us with our email marketing campaigns, notably Sendgrid;

• Subject to your consent when legally required, we may share personal information about you with our business partners or with other companies under common control, in which case they will be required to comply with this Policy;

• Aggregate information: We may share user information in aggregate form with third parties, notably with advertisers and content distributors. For example, we may disclose the number of users who have been exposed to or clicked on advertisements;

• If you report or send a claim to Michelin concerning the content provided on the Service, we may share the essence of your claim with the contributor responsible for that content in order to give him/her the opportunity to respond to it;

• We shall also respond to requests for information if we are legally required to do so, or if such a disclosure is needed to protect our rights and/or to comply with a legal procedure, a court ruling, a request from regulatory body, or any other legal proceedings filed against us.

• Links: The Service may contain links to unaffiliated third-party services. Unless otherwise provided for herein, we shall not share your personal data with these third-parties, and we are not responsible for their practices as regards privacy. We recommend you read the privacy policies on the websites of all the third-party services concerned, or that apply to them. Facebook and Twitter: if you link your account for the Application to the account of a third-party service, such as Facebook or Twitter, we may receive information about you from those third-party services. We may use this information to help you create your account on the Application and to link and share your public content with your friends and subscribers. You can manage how you link your account to third-party services. Please note that if you interact with Facebook, Twitter or other third-party icons through the Service, including "like", "share" buttons or other comparable features, these companies may collect information about you, notably your device's IP address. Your interactions with these and other third parties are governed by their privacy policies.

• Data transfer: if your Personal Data are transferred to service providers outside the EEA (European Economic Area), we shall take steps to ensure that your Personal Data benefit from the same level of protection as if they had remained within the EEA, including establishing data transfer contracts, on the basis of the latest amended or updated Standard Contractual Clauses approved by the European Commission, or through the use of certification programs - for transfers to the United States - or other transfer mechanisms, such as adequacy decisions, Binding Corporate Rules or contracts approved by the EU Data Protection Authorities, where relevant. You have the right to obtain information about the transfer mechanism through which your Personal Data are transferred outside the EEA and the country to which such a transfer is made by contacting [email protected].

For your information, to date, your Personal Data (name and email address) are only transferred outside the EEA to our service provider Sendgrid for the purposes of managing email marketing campaigns.

• Personal Data represent an asset covered by transfer operations in the event of a merger, acquisition, partial contribution of assets or any other change of control concerning the Application. Users shall be notified of this transfer, as well as the alternatives offered concerning the fate of their Personal Data, as soon as possible by message posted on the Website and/or by email, if Users have previously provided their email address.

5. Control of your Personal Data

Other users may be able to identify you, or associate you with your user account if you include personal information in the content you post. You can reduce the risk of being personally identified by using the Service under a pseudonym, although, by doing so, you risk damaging the credibility of your contributions to the Service.

6. Storage of your Personal Data

You can close your account at any time by emailing us at [email protected].

We will then block the display of the articles you have published and/or dissociate them from your account profile.

We may store your Personal Data under the following conditions:

• We shall store your Personal Data for as long as is strictly required to fulfill the purpose for which they were collected, i.e. as long as you use the Service;

• We shall store your Personal Data for marketing purposes for three years from the date of the last interaction between you and us, unless you directly object to this when you receive one of our messages;

• The IP addresses collected for security purposes shall not be stored for more than 10 days;

• Provided you agree, the connection logs that are collected shall be stored, using cookies and other trackers used as part of the Service, for a period not exceeding thirteen (13) months in accordance with applicable laws and regulations. For more details, please refer to the "Cookies" section below.

• We may need to store your Personal Data in an archive for longer than the period specified below in order to comply with our legal obligations or, if necessary, in accordance with the applicable statute of limitations, to protect our rights.

• Once your Personal Data are no longer required for the purposes of the Service or for archiving purposes, so as to fulfill our legal obligations or the requirements of the applicable statute of limitations, we shall ensure that they are completely destroyed or anonymized.

If you allow us to have access to your contacts, we may transmit this information to the Application for the length of time necessary to process your invitations. Please note that companies cannot delete registration data concerning points of interest, assessments or comments about points of interest when closing their accounts, unless otherwise specified by the law or regulations.

7. Minor

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

8. Securities

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.

9. Your rights

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 transfer information

The right to object to processing

The right to give instructions beyond your death ( if provide by your national law)

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

If your personal information is inaccurate or incomplete, you are entitled to have that information corrected and updated. If we have disclosed your information to any third parties, where possible, we will inform them of any updates you provide to us. You can update the personal information we hold about you by contacting us using any of the contact methods details in this Privacy Policy.

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.

There are some limited circumstances 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 transfer information

If you want to move or transfer your personal information to a different service provider or copy your information for your own purposes, you have the right to have your information transferred to another person.

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 [email protected].

The right to define the outcome of your personal information after your death

Only applicable in some EU countries ( exemple France) regarding applicable national law. You can have the right to give us instructions on what we wish that we do with your personal information after your death. We will register it and if we heard that such event occurred, we will comply with your instructions.

For further information on your rights

You can find further information on your data protection rights from the website of your supervisory authority.

To exercise your rights you can contact us to [email protected]

10. Cookies

A cookie is a text file or a software element which records information relating to the navigation of your terminal on the Internet. It is under the control of your browser, and sometimes carries a unique and random number.

When Michelin mentions "cookies", these may be cookies or other similar technologies which are based on access to the device that you use (computer, tablet, smartphone) when visiting our websites. Third parties such as our partners and service providers may use cookies and similar technologies in connection with our Services.

A cookie allows Michelin or its partners, as issuers of cookies and during its period of validity, to recognize your device each time it accesses digital content containing cookies from the same issuer.

For more information on please read our Cookie Policy

11. Contact

If you have question on this privacy policy, please contact [email protected]

12. 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 2021