Truckfly Privacy Policy

Thank you for your interest in Truckfly by Michelin (the "Application" or the website) and its services.

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

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

1. Who are we?

The Service is offered by Manufacture Française des Pneumatiques Michelin, a company with a capital of 504,000,004 euros, registered under number 855 200 507 RCS Clermont-Ferrand, and whose registered office is located at Place des Carmes Déchaux, 63040 Clermont-Ferrand Cedex 9. Acting as the data controller for your Personal Data collected in connection with the use of the Service.

2. Personal Data we collect

In the context of your use of the Service, we collect:

• Account Data: If you create an account on the Application, we may store and use your full name, age, email, and phone number. Your first name and the initial of your last name, as well as any photos you submit during registration, will be made public as part of your account profile. If you believe an unauthorized account has been created representing or impersonating you, you can request its deletion by contacting us.
• Your ratings, comments, favorites, "likes," modifications and additions of places, account profile.
• Your contact list: You can invite your friends to join the Service by allowing us to access your contacts from your mobile device or from third-party sites, to select the friends you wish to invite.
• Marketing Data: If you indicate your wish to receive additional information by subscribing to one of our newsletters or commercial communications, marketing data is processed with the aim of sending you relevant communications and/or newsletters according to your wishes. We will ask for your name, email, and/or phone number to send you the requested communications. We will send you communications only if you have given us your consent, or unless you object, where permitted by law. You can manage your communication preferences in the "Settings" section of the Application. We may track your actions in response to messages you receive from Michelin or through the Service, including when you delete, open, or forward these messages. Please note, however, that you cannot opt-out of receiving certain administrative or legal notifications from Michelin.
• Data relating to your CV: identification data, contact details, professional experience, training/qualifications/languages spoken, type of license, and type of travel.
• Company Data: (i) If you are the representative of a company listed on the Application, we may contact you, including by phone or email, using the contact details you provide that are presumed professional, that you make publicly available, or that we have recorded for your establishment. (ii) If you are the representative of a professional Truckfly client who has subscribed to our heavy truck navigation Services or Truckfly JobBoard.
• Contact Data: If you decide to contact us, we may record the data you provide in your message.
• Activity and geolocation: We may store data relating to your use of the Service, such as your searches, the pages you view, the date and time of viewing, and the companies you contact using our Application. We may also store data relating to your use of the Service that your computer or mobile device provides to us, regarding, for example, your browser type, computer or mobile device type, browser language, your IP address, your mobile operator, your unique device identifier, your geographical location (including geolocation, beacon location, and GPS location), as well as requested URLs and referring URLs. You may be able to object to our use of certain location data in the "Privacy" section of the Application or through your mobile device or browser settings, for example by disabling "Location Services" for the Application in your device's privacy settings. In the context of using our heavy truck navigation service, we invite you to consult the "Heavy Truck Navigation Service" section.

Some of this information is mandatory to identify you when creating your account. In the event that you do not provide mandatory information, your user account cannot be created. Mandatory information will be indicated as such in the forms.

3. Why and how do we use your Personal Data?

We use your Personal Data for specific purposes, each based on a legal basis, as detailed below:

Purpose of Processing	Legal Basis
To provide you with the Service and ensure its proper functioning.	The Service is provided on the basis of our General Terms of Use that you accept by subscribing to the Service. We therefore need to process your Personal Data to fulfill our obligations under this contractual relationship. Some features of the Service require the use of geolocation, which is based on obtaining your consent.
To improve the quality of the Service, market it, and develop it.	We have a legitimate interest in providing you with the best Service and in developing our activities.
To monitor the use of the Service and personalize your experience.	We have a legitimate interest in providing you with the best Service and in seeking to better meet your expectations and needs.
To conduct a survey or poll.	We have a legitimate interest in monitoring and improving the products and services provided to customers and users by Michelin or its partners.
To respond to your requests and follow up appropriately, communicate with you for marketing operations.	We have a legitimate interest in responding to your needs and requests. The use of your Personal Data for prospecting purposes is based on our legitimate interest in developing our relationships with you. We will send you communications only if you have given us your consent, or unless you object, where permitted by law.
To provide you with customer support.	We have a legitimate interest in providing you with assistance based on your explicit request.
To ensure and improve the security of the Service, particularly by backing up our systems and enabling disaster recovery.	We have a legitimate interest in protecting the security of our assets and Service.
To preserve our rights and assets, including those of other users of the Service.	We have a legitimate interest in preserving our rights and ensuring the security of our assets and Service, as well as that of our users.
To comply with our legal obligations, any court decision or other legal procedure, as well as the requirements of regulatory authorities.	We may use your Personal Data in the context of a commercial transaction, to assert our rights in court, or to protect the rights of third parties, which is based on our legitimate interest or that of a third party. With regard to the other purposes described in this section, we are obliged to use your Personal Data in order to comply with the legal obligations applicable to us.

4. Communication and transfer of your Personal Data

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

• Third parties to whom we outsource certain services, including, but not limited to, IT service providers or publishers, IT support providers;
• Third-party providers to assist us with customer data analysis, for example Google Analytics and Flurry;
• Third-party private messaging providers who assist us in our email campaigns, particularly Sendgrid, Brevo, or others, or to push information directly into the Application like Onesignal;
• Third-party providers for the provision of heavy truck navigation Services such as the company HERE Europe B.V. For more information, please consult HERE's personal data protection policy: https://legal.here.com/en-gb/privacy;
• Subject to your consent where legally required, we may share information about you with business partners or other companies under common control, in which case we will require them to comply with this Policy;
• Aggregated Information: We may share aggregated user information with third parties, including advertisers and content distributors. For example, we may disclose the number of users who were exposed to or clicked on advertisements;
• If you report or address a complaint to Michelin concerning content on the Service, we may share the essence of your complaint with the contributor of that content to give them an opportunity to respond;
• We will also respond to requests for information if required by law, or if such disclosure is necessary to protect our rights and/or comply with a legal proceeding, court order, regulator's request, or any other legal proceeding against us.
• Links: The Service may contain links to unaffiliated third-party services. Unless otherwise provided herein, we will not share your personal information with them, and we are not responsible for their privacy practices. We suggest you read the privacy policies on the websites of all relevant third-party services or those applicable to them, such as Meta (Facebook) and LinkedIn.
• If you link your Application account to a third-party service account like Meta (Facebook), Apple, Google, we may receive information about you from these third-party services. We may use this information to help you create your account on the Application and to connect and share your public content with your friends and followers. You can manage how you link your account to third-party services. Please note that if you interact with Meta (Facebook) and LinkedIn, or other third-party icons through the Service, including "like" buttons, "share" buttons, or other comparable functions, these companies may collect information about you, including 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 is transferred outside the EEA (European Economic Area) to service providers, we will take steps to ensure that your Personal Data benefits from the same level of protection as if it had remained within the EEA, including by entering into data transfer agreements based on the Standard Contractual Clauses approved by the European Commission as updated or revised, or by using certification programs for transfers to the United States or other transfer mechanisms such as, where applicable, adequacy decisions, Binding Corporate Rules, or contracts approved by EU Data Protection Authorities. You have the right to obtain information regarding the transfer mechanism by which your Personal Data is transferred outside the EEA and the country to which this transfer is made by contacting truckfly@michelin.com.
• Personal Data constitutes an asset covered by transfer operations in the event of a merger, acquisition, partial transfer of assets or other change of control concerning the Application. This transfer, as well as the alternatives offered to the User concerning the fate of Personal Data, will be notified to him as soon as possible by message posted on the Site and/or by email, provided that this address has been previously communicated.
• We may also be required to share certain personal data about you with authorized third parties (i.e., depending on the case, authorities, administrations and/or bodies authorized by legislative or regulatory provisions to demand the communication of documents or information containing personal data). This is part of our compliance with any legal obligation, such as the recovery of a road traffic offense following a vehicle test, or in execution of an administrative or judicial decision.

5. We collect your data via third parties

We may obtain data about you through third parties outside the Michelin Group, after they have informed you and, where required, with your prior consent. These third parties may be:

• Private database publishers, if you have agreed to transmit your personal data.
• Third-party identity services, such as Google, Facebook, Apple, for authentication on our sites or applications. The shared data depends on the platform of these providers. To access the data protection policies of these providers, click on the name of the provider that interests you: Google (https://business.safety.google/privacy/), Facebook (https://fr-fr.facebook.com/help/218345114850283/?helpref=uf_share), Apple (https://www.apple.com/fr/legal/privacy/fr-ww/).
• Business partners, after prior information or subject to your consent.

6. 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 publish. You can reduce the risk of being personally identified by using the Service with a pseudonym, although by doing so, you risk undermining the credibility of your contributions to the Service.

7. Retention of your Personal Data

You can close your account at any time by sending us a request by email to truckfly@michelin.com.

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

We may retain your Personal Data under the following conditions:

• We will always retain your Personal Data for the period strictly necessary to achieve the purpose for which it was collected, i.e., as long as you use the Service;
• We will retain your Personal Data for prospecting purposes for three years from the date of the last interaction between us unless you object when you receive one of our messages;
• IP addresses collected for security purposes will not be retained for more than 10 days;
• Connection logs that are collected will be retained, provided you consent, using cookies and other trackers used in the Service, for a period not exceeding thirteen (13) months in accordance with applicable laws and regulations. For more details, refer to the "Cookies" section below.

We may need to retain your Personal Data in archive form beyond the period indicated below to comply with our legal obligations or if it is necessary given the applicable statute of limitations, to assert our rights.

Once your Personal Data is no longer necessary for the purposes or for archiving to satisfy our legal obligations or for the needs of the applicable statute of limitations, we will ensure that it is either completely destroyed or anonymized.

If you allow us to access your contacts, we may transmit this information to the Application for the time necessary to process your invitations. Please note that companies cannot delete registration data for points of interest, ratings, or comments regarding points of interest when closing their accounts, unless legal or regulatory provisions dictate otherwise.

8. Minors

The Service is intended for all audiences but is not designed for individuals under 16 years of age. We do not knowingly collect any personal information concerning children under 16. If you learn that a child under 16 has provided us with personal information without parental consent, we will take the necessary steps to delete such information and will close the child's account.

9. Security

We adhere to generally accepted industry standards to protect personal information provided to us, both during transmission and once received. Nevertheless, no method of transmission over the Internet or via a mobile device, nor any method of electronic storage, is 100% secure. Therefore, even if we strive to use commercially acceptable means to protect personal data, we cannot guarantee absolute security.

10. Your Rights

In accordance with applicable law, you benefit from the following rights regarding your Personal Data:

• A right to access your Personal Data, including the right to obtain a copy thereof, as well as information on the processing methods of Personal Data and their legal basis;
• To rectify your inaccurate Personal Data (including the right to complete incomplete Personal Data);
• To erase your Personal Data (this right can only apply when it is no longer necessary to achieve the purposes for which it was collected or processed);
• To restrict the processing of your Personal Data when:
  • you dispute the accuracy of your Personal Data we process;
  • the processing is unlawful but you object to the erasure of your Personal Data;
  • we no longer need your Personal Data but it is still necessary for the establishment, exercise, or defense of a legal claim;
• To request the portability of your Personal Data in a machine-readable format for a third party (or for yourself) if our processing is based on your consent or on the performance of a contract concluded with you;
• To give general or specific instructions on the processing and use of your Personal Data after your death;
• To object at any time to any telephone contact for prospecting purposes, by registering free of charge on the Website: bloctel.gouv.fr;
• To withdraw your consent to the processing of your Personal Data at any time (if this processing is based on your consent) without affecting the lawfulness of processing based on consent before its withdrawal;
• In addition to the aforementioned rights, you have the right to object to any processing of your Personal Data justified by Michelin's legitimate interest, including profiling (as opposed to a justification by your consent, or to perform a contract with you). You also have the right to object to any processing of your Personal Data for prospecting purposes, including profiling.
• To obtain or consult a copy of the appropriate measures taken to transfer your Personal Data to a third country or an international organization.
• You also have the right to lodge a complaint with your local data protection supervisory authority. For France: the CNIL 3 Place de Fontenoy, 75007 Paris, France.

To exercise these rights, please contact us using the contact details below, under the "Contact" section or the "Exercise your rights" section of the Application and the Website. Please note that we may ask for proof of identity, and we reserve the right to charge a fee if the law allows us to do so, for example if your request is manifestly unfounded or excessive. We will endeavor to respond to your request within the applicable time limits.

11. Cookies

A cookie is a small file that can be placed on the hard drive of your device or on the server of a website. We use cookies to obtain certain automatically collected information described above. You are not obliged to accept a cookie, and you can choose which cookie to accept by changing your browser settings so that it does not accept cookies. For more information on cookies, including how to configure your Internet browser to refuse them or to better control the installation of cookies on your device, please go to the cookie settings module accessible in the footer of the site and/or in the settings of the mobile application. (https://www.truckfly.com/cookies/)

Cookie Management and Deletion

In order to control the use of cookies on our Website, we have implemented a tool that is offered to you when you access our Website and which invites you to configure the different cookies whose installation you have authorized. We thank you for consulting the cookie settings module. If you refuse cookies, we will no longer place other cookies on your device, except for the "functional" cookies presented above (including, in particular, a cookie allowing us to remember that you do not want cookies to be installed when you visit the Website).

12. Contact

If you have any questions regarding this Policy or wish to exercise any of your rights, please contact our Personal Data Protection Officer by email at: privacy[.]fr[@]michelin[.]com

13. Modifications to this Policy

We may revise this Policy to take into account changes in law and/or our practices regarding the protection of Personal Data.

Last updated: June 2025