Prometeon Privacy Policy

Last modified: March 2021

1. Introduction

 Prometeon Tyre Group S.r.l. (“Prometeon”, “us”, “our” or “we”) respects your privacy and is committed to protect it through our compliance with this policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website https://website.prometeon.com/US/en_US and its subdomains (each, a “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• on our Website;
• in email, text, and other electronic messages between you and our Website; and
• when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• us through any other means, including on any other website operated by Prometeon or any third-party (including our affiliates and subsidiaries); or
• any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

2. Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to the Website. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Website or on or through any of its features, including your name, telephone number, or email address. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at [email protected].

3. Information We Collect About You and How We Collect It

Generally

We collect several types of information from and about users of our Website (“Personal Data”):

• by which you may be personally identified, such as name, address or zip code (to find a local dealer), e-mail address, and telephone number;
• for our dealerships customers and their employees we may collect identification and contact data, such as your company and employee names, tax code, VAT number, email, telephone and fax number, and address, business information, such as main activities, business sector, services, and customer payment methods, commercial information, such as purchase, billing and payment information, and any other information you provide that when you interact with us; and
• about your Internet connection, the equipment you use to access our Website and usage details, such as traffic data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website.

We collect this information:

• directly from you when you provide it to us;
• automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and
• From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website are:

• information that you provide by filling in forms on our Website, such as information provided at the time of requesting further information about our products, or when you report a problem with our Website. Additionally, we may also collect information from our dealership partners through forms about the dealership to post on our Website for our dealer locator feature;
• your search queries on the Website; and
• records and copies of your correspondence (including email addresses), if you contact us.

The Personal Data we collect from you is required to provide you with our services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to provide you with our services through the Website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:

• details of your visits to our Website, such as traffic data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website; and
• information about your computer and internet connection, i.e. your IP address, operating system, and browser type.

The information we collect automatically may include Personal Data and we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Website according to your individual interests;
• speed up your searches; and
• recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). We may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Website through your computer or mobile device. Details about the automated data collection technologies and the specific cookies that we use can be found in our Cookie Policy available at https://website.prometeon.com/US/en_US/legal/cookies.
• Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Website. Google Analytics uses cookies to help the Website analyze how users use the site. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners' sites or apps”, (located at google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.

 4. How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Data:

• to present our Website and its contents to you;
• to provide you with information, products, or services that you request from us;
• to fulfill any other purpose for which you provide it;
• in any other way we may describe when you provide the information; and
• for any other purpose with your consent.

5. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this Privacy Policy:

• to our subsidiaries and affiliates, including Prometeon Group Companies;
• to contractors, service providers, and other third parties we use to support our business. These entities provide IT and infrastructure support services;
• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Prometeon’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Prometeon about our Website’s users is among the assets transferred;
• to fulfill the purpose for which you provide it, for example to allow potential customers to find you by listing the contact information for your dealership or dealership employee on our Website;
• to carry out our obligations and enforce our rights arising from any contracts entered into between us and a dealership or a dealership employee, including for billing and collection
• for any other purpose disclosed by us when you provide the information; and
• with your consent.

 

We may also disclose your Personal Data:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our terms and conditions of use available at https://website.prometeon.com/US/en_US/legal/terms-and-conditions and other agreements, including for billing and collection purposes; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Prometeon, our customers, or others.

6. Choices About How We Use and Disclose Your Information

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.
• Promotional Offers from Prometeon. We may also use your information to contact you about our other products and services that may be of interest to you. If you wish to opt-out of receiving emails from us, you may do so at any time by selecting unsubscribe at the bottom of our emails. This opt out does not apply to information provided to Prometeon as a result of a product purchase by a dealer.

You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

7. State Specific Privacy Rights

The law in some states may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these states, please see the privacy addendum for your state that is attached to this Privacy Policy.

8.  Do Not Track Signals

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

9. Data Retention Periods

Prometeon will retain your Personal Data in accordance with our data retention policies. We may retain your Personal Data:

• for as long as necessary to comply with any legal requirement;
• on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
• for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
• for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.

10. Changes to Our Privacy Policy

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ Personal Data, we will notify you by posting a notice on the Website’s home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes.

11. Contact Information

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below or through the “Let’s Talk” feature on our Website.

To Contact Prometeon

Prometeon

100 Pirelli Drive

Rome, GA 30161

[email protected]

 

 

Prometeon Privacy Addendum for California Residents

Effective Date: March 2021

Last Reviewed on: March 2021

This Privacy Addendum for California Residents (“Privacy Addendum”) supplements the information contained in Prometeon Privacy Policy that this is attached to and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. Personal Information that is regulated under the CCPA may represent a limited portion of Personal Data as described in the Prometeon Privacy Policy; therefore, this Privacy Addendum applies solely to the Personal Information as defined below. We may update this Privacy Addendum as necessary and in the event of changes in the CCPA. Note that this notice does not apply to our personnel. Please contact your supervisor if you are personnel and would like additional information about how we process your personal information.

 

INFORMATION WE COLLECT

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, Prometeon collects and has collected Personal Information through its Website from its consumers, as provided below.

Categories of Personal Information Prometeon has collected in the preceding 12 months:

• Identifiers (e.g., name, mailing address, email address, unique personal identifier, online identifier, Internet Protocol address (IP address), or other similar identifiers)
• California Customer Records Personal Information categories (e.g., name, address, telephone number. Note, some of this information may overlap with other categories)
• Commercial information (e.g., records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
• Internet or other similar network activity (e.g., browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement)
• Geolocation data (e.g., physical location)
• Inferences drawn from other Personal Information (e.g., profile reflecting a person’s preferences)

Personal Information does not include information that is: (a) publicly available information from government records; (b) deidentified or aggregated consumer information; or (c) certain information excluded from the scope of CCPA, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Categories of sources from which Prometeon has collected Personal Information:

• Directly from you. For example, from forms you complete when requesting information about our products
• Indirectly from you. For example, from our operating systems and platforms
• Affiliates, parents and subsidiary organizations of Prometeon
• Service providers

 

USE OF PERSONAL INFORMATION

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example: if you share your name and contact information to ask a question about our products, we will use that Personal Information to respond to your inquiry. We may also save your information to recognize you when you return to our Website.
• To provide, support, develop and improve our Website, products, and services.
• To process your requests for information and for our dealership customers purchases, transactions, payments and to prevent transactional fraud.
• To deliver content and product and service offerings relevant to your interests, including targeted offers and ads through email.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and to monitor and improve our responses.
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity, and to debug to identify and repair errors that impair existing intended functionality.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• Undertaking internal research for technological development and demonstration.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Prometeon assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Prometeon about our customers are among the assets transferred.

Prometeon will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

DISCLOSURES OF PERSONAL INFORMATION

We do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate your Personal Information to another organization for monetary or other valuable consideration. However, Prometeon may disclose your Personal Information to a third party for one or more business purposes. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a business purpose:

In the preceding twelve (12) months, Prometeon has disclosed the following categories of Personal Information for a business purpose:

• Identifiers
• California Customer Records Personal Information categories
• Commercial information
• Internet or other similar network activity
• Geolocation data
• Inferences drawn from other Personal Information

We disclose your Personal Information for a business purpose to the following categories of third parties:

• Service providers
• Affiliates

Sales of Personal Information:

In the preceding twelve (12) months, Prometeon had not sold Personal Information.

 

YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access request rights

You have the right to request that Prometeon disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access and Deletion Rights), we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you.
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
  • sales, identifying the Personal Information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion request rights

You have the right to request that Prometeon delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the request for which we collected the Personal Information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
5. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
6. Comply with a legal obligation.
7. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access and Deletion Rights

To exercise the access and deletion rights described above, please submit a verifiable consumer request to us at:

• Emailing us at [email protected].

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf (an “Authorized Representative”), may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an Authorized Representative. Before completing your request to exercise the below, we will verify that the request came from you by asking you one or more knowledge-based questions about you.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. With few exceptions, we will only review and fulfill a request from your Authorized Representative if (a) you grant the Authorized Representative written permission to make a request on your behalf, (b) you or the Authorized Representative provides us notice of that written permission, and (c) we are able to verify your identity in connection with that notice and the request.

Making a verifiable consumer request does not require you to create an account with us.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12 month period preceding the verifiable consumer request s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will choose a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

We do not sell the Personal Information of consumers and therefore do not provide any opt-in or opt-out capabilities on our Website or otherwise.  

 

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

CHANGES TO OUR CALIFORNIA ADDENDUM

We reserve the right to amend this Privacy Addendum as described in our Privacy Policy. When we make changes to this Privacy Addendum, we will inform you of such updates as described in our Privacy Policy.

 

 

Prometeon Privacy Addendum for Nevada Residents

Effective Date: March 2021

Last Reviewed on: March 2021

Prometeon respects your privacy and is committed to protecting it through our compliance with this policy.

Prometeon does not sell your personal information to any outside companies; therefore, Prometeon does not provide any opt-out capabilities on our Website or otherwise.

You are entitled, nevertheless, under Nevada law to formally request that we not sell any of your personal information. Please email us at [email protected] to submit your request and we will confirm your request.