Privacy Notice

Summary

Camso is committed to protecting your personal information and being clear and transparent about what information we collect and how we will use it. This notice 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.

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

If you are a resident of California, Colorado, Connecticut, Nevada, Utah, or Virginia, please see our Additional U.S. Privacy Disclosures for additional privacy disclosures that apply to you.

1. Who we are and how we can be contacted
2. About our Data Protection Officer
3. Other policies and information we encourage you to read
4. Information we may collect from you
5. Marketing Communications
6. Information we collect about you from other places
7. Sharing your personal information
8. International transfers of personal data
9. How long will personal information be kept by us
10. Your rights under data protection legislation
11. What you can do if you’re not happy
12. About Data Security
13. Updates to our Privacy Notice
14. Contact us
15. Additional U.S. Privacy Disclosures

1. Who we are and how we can be contacted

Our full company name is Camso Inc. (“Camso”) and when you use our website and our services directly, we act as a Data Controller.

If you need to contact us, you have two options:

• email us at: privacy.amn@michelin.com

• mail us a letter to: Camso Inc., Attn: Legal Department, 2633, rue MacPherson, Magog, (Québec) J1X 0E6 Canada

2. About our Data Protection Officer

While everyone at Camso is committed to protecting and respecting your privacy, we have a data protection Privacy Department who deals with all aspects of personal information at Camso.

Michelin North America, Inc.

Att: Privacy Officer
One Parkway South
Greenville, SC 29615

You can also contact our Privacy Department by sending an email to: privacy.amn@michelin.com

3. Other policies and information we encourage you to read

While this Privacy Notice 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

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

• Our Cookie Notice

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 Notice which explains our use of cookies and the purposes for which we use them. We encourage you to read our Cookie Notice here: https://camso.co/en/about/cookie-notice.

• Terms of use

Our Website Terms of Use tells you about the terms on which you may make use of our websites and should be read alongside this Privacy Notice. You can read our Website Terms of Use here https://camso.co/en/about/legal.

• Linked platforms

Our site may contain links to and from our third-party websites, plug-ins, and applications, including the 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 except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn more about the personal information practices of third parties, please check their respective privacy policies before you submit any personal information to these websites.

4. Information we may collect from you

This section sets out:

• how we collect your personal information;
• the categories of data that we collect;
• a description of how we plan to use the information we collect; and
• the legal basis that we will rely on to process information collected.

We may collect and hold the information about you in the table below. If you reside in the European Economic Area or the United Kingdom, the lawful basis of processing is set out in the “Lawful basis for processing” column below. In other jurisdictions, such as Canada, the primary legal basis for the collection and use of your personal information is your express or implied consent. However, where the processing of personal information involves sensitive personal information in Canada or involves profiling you, collecting your geolocation or using technologies to identify you, we will obtain your explicit consent. In these jurisdictions, you may opt-out of the use of your personal information if it is not necessary to communicate with you, to provide you with the products and services you request, to meet our legal obligations or to protect our rights.

• 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 and our affiliates business purposes only.

• Sensitive Personal Information

Certain of the personal data elements we collect may be classified as “sensitive” under certain privacy laws, such as account name and password, financial account number, and credit or debit card number plus expiration date and security code (CVV). While we generally do not request other types of 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 sections, 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 other 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 14, 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 14) has provided their personal information to us, without your consent, please let us know as soon as possible by emailing privacy.amn@michelin.com so that we can take appropriate action.

• Segmentation and Targeting

As part of our services, Michelin may need to create user groups to better target the offers and communications sent.

The segments or profiles are produced based on information held by Michelin or the companies of the Michelin group (account data, navigation data, purchase data, declarative data) or information collected in the context of our relations with partners (e.g., social networks, etc.).

Michelin undertakes not to use, for segmentation and targeting purposes, personal data likely to reveal racial or ethnic origin, political opinions, religious or philosophical convictions or trade union membership, as well as genetic, biometric, health data or data relating to the sexual life or sexual orientation of a natural person, in accordance with applicable laws.

5. Marketing Communications

Subject to local legal requirements, you will 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 or if (iii) this communication is linked to your business activity.

You can unsubscribe or stop direct marketing from us at any time by either

(i) clicking on the unsubscribe option at the bottom of each marketing communication we send to you; and

(ii) contacting us by email or letter using any of the contact details set out in this notice.

If we have a legal basis to send you marketing communications, we will generally send you those communications until you choose to unsubscribe from receiving them.

From time to time, we may also use your Usage and Device Data (as defined below) to make online suggestions and recommendations to you about goods or services that may be of interest to you. Unless local law requires us to obtain your consent, we will use your Usage and Device Data in this way as it is. This is necessary for the legitimate interest of our business in developing our products and services and growing our business.

6. Information we collect about you from other places

To 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 of the other websites we operate or the other products and/or services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment services, analytics providers, search information providers and credit reference agencies) and if permitted by you or as permitted by applicable law, we may receive information about you from them. Subject to local legal requirements, the legal basis for this processing is our legitimate interests, namely monitoring and improving our website, products, and services.
• We and our third-party providers may collect information from our web servers’ logs, for example information about your computer, such as your IP address, operating system, and browser type. We and our third-party providers may also collect information about how you interact with our services, including on the searches you carry out on our website and your interaction with communications we send you, for example, when you open email communications, interact with/message using our chat function, or interact with one of our automated tools (“Usage and Device Data”). This information is used by us and our third-party providers for system administration, product improvement (including training and refining automated tools leveraging artificial intelligence) and to analyze how people are using our websites and digital platforms. It also helps us to provide the best online infrastructure for your online activities. Subject to local legal requirements, which may require explicit consent, the legal basis for this processing is our legitimate interests, namely monitoring and improving our website, products, and services.
• As mentioned above, we collect information using cookies or other similar technologies stored on your device about how you use our website, digital products, and services. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our websites and deliver a better and more personalized service to you. You can read our Cookie Notice here: https://camso.co/en/about/cookie-notice.
• Our website may enable you to share your experience and connect with us through third party social networks such as Facebook and Twitter. We may collect this information from our social media sites, including likes, shares, and tweets, and about the content on social networking sites. We do not control the privacy of the information you provide on social media networks and the privacy policies of those social media networks will apply when using their services.

7. Sharing your personal information

We may share your personal information with the following:

• Within the Michelin Group – Camso is part of 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 notice. Your contact data (email address, interests) can be shared with Michelin Group companies to know you better and personalize the experience that Michelin companies can bring you and send you marketing offers and communications related to the newsletters to which you have subscribed.
• Service Providers - Camso may share your personal information with selected service providers that Camso 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 obligated to keep the personal information they may have received confidential and secure and to use your personal information based on our instructions only.

• We may also share your personal information with third parties:
  (i) 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 Camso or 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.
  
  (ii) On the basis of your consent:
  Third parties can collect information about you on our website, products or services via cookies or similar technologies, for example to provide certain technological features, personalized ads or to make profiling. These cookies will be accepted by you in accordance with our Cookie Notice. You can read it here: https://camso.co/en/about/cookie-notice.

8. International Transfers of Personal Data

Camso is headquartered in Canada and is part of the Michelin Group which is an international group with databases in the various countries in which it operates. Camso may transfer your personal data within the group to one of its databases or to its external partners located outside of your home country. We take steps to ensure that our transfers of data are lawful by, for example, entering model contracts approved by the European Commission, called the Standard Contractual Clauses, through Binding Corporate Rules or based on specific consent or as otherwise permitted by applicable law.

9. 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.

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 unauthorized 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 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 further notice to you.

10. Your rights under data protection legislation

The data protection legislation of your jurisdiction may provide you with certain rights when it comes to the processing of your personal information. The rights listed below may not all apply to you as your rights with regards to personal information depend on your jurisdiction. While some of these rights listed below apply generally, certain rights apply only in limited cases or under your applicable local law. They may or may not apply to you depending on your jurisdiction.

• 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 (data portability)
• The right to object to processing
• The right to give instructions beyond your death

If you are a resident of California, Colorado, Connecticut, Nevada, Utah, or Virginia, please see the “Additional US Privacy Disclosures” for more information on the privacy rights that may be afforded to you.

• The right to be informed

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

The right to access the personal information we have on you. We can confirm whether 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 detailed in this Privacy Notice.

• The right to delete your information

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 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 (data portability)

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

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.

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

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 privacy authority of your jurisdiction.

11. 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:

• email us at: privacy.amn@michelin.com
• You can send us a letter addressed to: Camso Inc., Attn: Legal Department, 2633, rue MacPherson, Magog (Québec) J1X 0E6 Canada

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 may also make a complaint to the privacy authority of your jurisdiction. For example, if you are Canadian, you can make a complaint to the Office of the Privacy Commissioner of Canada – further information can be found at https://www.priv.gc.ca/en/ or with the privacy authority of your jurisdiction

12. About Data Security

Camso has implemented reasonable and appropriate technical and organizational measures designed to protect the privacy, security, and integrity of your personal data.

13. Updates to our Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this notice, we will change the “Last Updated” date at the beginning of this Notice. If we make material changes to this Notice, we will notify you by updating the “Last Updated” date or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

14. Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy.amn@michelin.com.

Alternatively, inquiries may be addressed to:

Camso Inc.
Attn: Legal Department
2633, rue MacPherson, Magog
(Québec) J1X 0E6
Canada

15. Additional U.S. Privacy Disclosures

Scope of Disclosures

For Nevada Residents: Chapter 603A of the Nevada Revised Statutes permits Nevada residents to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please email privacy.amn@michelin.com.

For California, Colorado, Connecticut, Utah and Virginia residents: Depending on your state of residency, these Additional U.S. Privacy Disclosures (the “U.S. Privacy Disclosures”) supplement the information contained in our Privacy Notice above by providing additional information about how Camso Inc. (“Camso”, “we”, “us”, or “our”) processes personal data and apply solely to individual residents of the State of California, Colorado, Connecticut, Utah, and Virginia (“data subjects” or “you”).

These U.S. Privacy Disclosures provide additional information about how we collect, use, disclose and otherwise process personal data of individual residents of the State of California, Colorado, Connecticut, Utah, and Virginia, in connection with our websites (the “Sites”) and other websites we own and operate that link to these U.S. Privacy Disclosures, and the related content, platform, services, products, and other functionality offered on or through our services (collectively, the “Services”).

Unless otherwise expressly stated, all terms in these U.S. Privacy Disclosures have the same meaning as defined in our Privacy Notice.

Personal Data

When we use the term “personal data” in these U.S. Privacy Disclosures, we mean any data or information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household or any other data or information that constitutes “personal data”, “personal information,” or “personally identifiable information.”

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 Section 4 (“Information we may collect from you”), Section 6 (“Information we collect about you from other places”), and Section 7 (“Sharing your personal information”) of our Privacy Notice to learn more.

We disclose or otherwise make available 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”), as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. Some of these practices may involve the “sale” of personal data, or the sharing or processing of personal data, for the purpose of facilitating targeted advertising. Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal data or the processing of personal data for purposes of targeted advertising (as described in the “Your Privacy Rights” section below).

Sensitive Information

The following personal data elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”):

1. Account name and password; and
2. Financial account number and/or credit/debit card number plus expiration date and security code (CVV).

As described in our Privacy Notice, we use account name and password, as well as payment card information to provide certain of our products and services.

We do not sell sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.

Deidentified Information

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.

Your Privacy Rights

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all the following rights:

Depending on your state of residency, you may also have the right not to receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, please note that the exercise of the rights described above limits our ability to process personal data (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner. In addition, the exercise of the rights described above may result in a different price, rate, or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

How to Exercise Your Privacy Rights

Please submit a request by:

• Filling out our online form; or
• Calling 1-888-971-3804

For certain requests, we will need to verify your identity and confirm you are a resident of a state that offers the requested right(s) before processing your request. 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 state 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 states.

To Exercise the Right to Opt Out of the Selling, Sharing or Processing of Personal Data for Targeted Advertising Purposes

We may sell or share personal data (including Identifiers, Commercial Information, Internet/Network Information, and Inferences) to certain third-party ad networks, social networks and advertising partners to deliver targeted advertising (also known as “cross-context behavioral advertising”) and personalized content to you on our Sites and Services, on other sites and services you may use, and across other devices you may use, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

The third parties to whom we sell or share personal data may use such information for their own purposes, in accordance with their own privacy statements, which may include reselling or sharing this information to additional third parties.

To facilitate these targeted advertising purposes, we and our third-party providers use cookies and related technologies to collect personal data about users of our Sites and Services. To exercise your right to opt-out as it relates to the use of cookies and related technologies that involve the sale of personal data or the use of personal data for targeted advertising purposes on our Sites and Services, please adjust your cookie preferences by unchecking the “Targeting and Advertising Cookies” option.

Please note these cookie options may be unchecked or opted out by default. In addition, this opt out tool is device and browser specific, so you will need to change your preferences on each device and browser you use to interact with the Site or Service you are visiting.

You can also opt out of cookie-based sales by businesses that participate in the DAA’s CCPA Opt-Out Tool by visiting https://www.privacyrights.info/. In addition, you may follow the other steps set forth in our Cookie Notice to further exercise control over cookies and related technologies. Lastly, you may exercise your non-cookie-related rights by following the instructions provided at the beginning of this “How to Exercise Your Privacy Rights” section.

Authorized Agent

In certain circumstances, you are 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. 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 state 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.

Appealing Privacy Rights Decisions

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by emailing us at privacy.amn@michelin.com with the subject line, “U.S. Privacy Request Appeal.”

California-Specific Privacy Disclosures

The following disclosures only apply to residents of the State of California:

Personal Data Collection

In the last 12 months, we may have collected the following categories of personal data:

• Identifiers, such as name, email address, telephone number, address, zip code, account username and password, or other similar identifiers.
• California Customer Records (Cal. Civ. Code § 1798.80(e)), such as credit/debit card information, bank account information or other payment information.
• Protected Classification Characteristics, such as age.
• Commercial Information, such information about products or services purchased or considered, whether you used a particular coupon code or promotion, information about the third-party dealer from whom you purchased a Camso product, and information about your use of the Services.
• Internet/Network Information, such as your browsing history, log and analytics data, search history and information regarding your interaction with our website.
• Geolocation Data, such as information about your physical location collected from geolocation features on your device, and location information, such as zip code, that you provide to the Services through our dealer locator tool.
• Sensory Information, such as pictures you provide or upload in connection with the Services, and the content and audio recordings of phone calls between you and Camso and/or you and our service providers, that we record where permitted by law.
• Professional/Employment Information, such as job title, department, employer or business, and trade or professional association membership information.
• Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99).
• Other Personal Data, such as information and content you post to the Services and other information you submit to us, including inquiry and communication information when you contact us. We may also collect certain information about your vehicle, such as VIN number, Department of Transportation (DOT) code, vehicle type, make, model and registration information, and tire depth and size information.
• Inferences, including information generated from your use of the Services reflecting predictions about your interests and preferences.

For more information about our collection of personal data, the sources of personal data, and how we use this information, please see Section 4 (“Information we may collect from you”) and Section 6 (“Information we collect about you from other places”) of our Privacy Notice.

Disclosure of Personal Data

As described in Section 7 (“Sharing of your personal information”) of our Privacy Notice, we disclose personal data to a variety of third parties for business purposes or we may sell or share your personal data to third parties for targeted advertising purposes, subject to your right to opt out of selling or sharing (see the Your Privacy Rights Section of these Disclosures, above).

In the previous 12 months, we have disclosed all the categories of personal data we collect, explained above, to third parties.

In the previous 12 months, we have also sold or shared for targeted advertising purposes the following categories of personal information to third parties, including third-party ad networks, social networks, and advertising partners, subject to your settings and preferences and your Right to Opt Out: Identifiers, Commercial Information, Internet / Network Information, and Inferences.

In addition, please see our Cookie Notice to learn more about how third-party advertising networks, social media companies and other third-party businesses collect and disclose your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our Services or otherwise engage with us.

Data Retention

For information on our data retention practices, please see Section 9 (“How long will personal data be kept by us?”) of our Privacy Notice.

Minors Under Age 16

We do not sell the personal data of consumers we know to be less than 16 years of age.

If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal data and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative).

Updates to These U.S. Privacy Disclosures

We will update these Additional U.S. Privacy Disclosures from time to time. When we make changes to this Disclosure, we will change the “Last Updated” date at the beginning of this Disclosure. If we make material changes to this Disclosure, we will notify you by updating the “Last Updated” date or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Last Updated: September 20, 2023