Policy Revision date: May 1, 2023
1. Who are we?
Bridgestone Europe NV/SA is a company incorporated under Belgian law with registered office at Da Vincilaan 1, 1930, Zaventem, Belgium and company number 0441.192.820.
Bridgestone Europe NV/SA operates as the main establishment in the European Union of the First Stop Group, which also includes our affiliates First Stop Europe NV in Belgium, First Stop West S.A.S. and First Stop Ayme S.A.S in France, First Stop Southwest S.A.U. in Spain, and First Stop Reifen & Autoservice AG in Switzerland (collectively referred to in this policy as "First Stop", "we", "us" or "our").
We operate a network of independent franchisees operating under the "First Stop" brand. First Stop franchisees are legally independent of us and, in your dealings with them, they process your data on their own behalf as data controllers or on our behalf as data processors.
2. What personal data do we process?
Personal data is information that identifies you as a natural person directly, or indirectly when combined with other information. We may interact with you in different ways and for different reasons, each of which involves the processing of personal data. Some data is provided voluntarily by you, on your own initiative or at our request. Other data is observed data that we collect from your interactions with our products and services, websites and social media.
3. Purpose and lawfulness of data processing
When you interact with us in connection with the online purchase of products or services, or when you purchase products or services at a point of sale in the First Stop network that we operate ourselves, we ask you to provide information about yourself that is necessary for the completion of the transaction such as your first name, your name, home address, shipping address, email address, phone number, account password, payment information, tax identification number, VAT number, make and type of vehicle you drive, license plate number, vehicle identification number, your choice of product and/or service. If you are an individual, the lawfulness of our processing is based on the sales contract. Without your personal data, we cannot fulfil our obligations or exercise our rights under the contract, nor can we fulfil our contractual obligation to provide you with after-sales support.
Your license plate number is required as the unique identifier linked to your vehicle. This information allows us to check, in an online database, the technical suitability of the tyres selected for the vehicle concerned or, if necessary, to store your tyres for the season if you use our tyre guarding services.
When you interact with us on behalf of a legal entity (e.g. your employer), most of the data we collect from the customer is not personal data. However, we collect your name, telephone number and business email address for accounting reference purposes and to be able to contact you as the client's representative. In this case, the lawfulness of the processing is based on our legitimate interest in formalizing the sale through the natural person representing the customer, obtaining a signature on the order form and being able to contact the customer for after-sales service.
If you purchase products and services online, we transfer all this data to the First Stop point of sale of your choice, which needs this information in order to be able to deliver the products and services ordered to you. In addition, it is in our interest and that of the chosen First Stop point of sale that customers respect the date and time of appointments. Also, we will send you an SMS and/or an email the day before to remind you of your appointment.
When you contact us for information about our products and services, our point of sale network, warranty or other general information, we process your contact details, your particular request or question and, where applicable, your purchase history. We process this data on the basis of our legitimate interest in fulfilling your requests, answering your questions or investigating your complaints.
Our website incorporates a chatbot application that serves our legitimate interest in responding quickly to user requests 24 hours a day. It is an AI-powered application that can mimic a real conversation with users in their natural language. When you use the chatbot, we collect the name by which you wish to be called, the content of the request you make in the application and, if necessary, your email address and license plate number. Your name is essential for the sake of courtesy, to allow the chatbot to address you by name. The chatbot may request your email address if the service is overloaded, or if it is unable to respond to your request and we need to respond to you with human intervention.
Depending on the nature of your request and the country from which you make it, the chatbot may ask you for your license plate number. This information is used exclusively to check the technical characteristics of your vehicle in an online database made accessible by the local authorities, in order to be able to recommend the right tyres for your vehicle.
Service report and mileage
After performing a service on your vehicle, our points of sale process information that may indicate behavioural data (abnormal wear, tire damage caused by driving style), and record the current mileage of the vehicle. This information is added to the invoice and/or service report and then communicated to the third party responsible for paying our invoices. We process this data in our legitimate interest in justifying the validation of the services we have performed on your vehicle.
In some countries, we have a legal obligation to enter the mileage, vehicle identification number and date of service provision into a central database managed under government control each time we perform a service on a vehicle.
Customer satisfaction survey
If you have an online account, we have a legitimate interest in occasionally inviting you to participate in a satisfaction survey to help us understand the general expectations and preferences of our customers. These surveys are necessary for the pursuit of our legitimate interest in keeping our products and services in line with market demands.
Point of Sale Locator
You have the option to search for a First Stop outlet in your area from our website. This app uses your geolocation as revealed by the IP address of the device used to perform the search. Geolocation is not your precise location but the wider area, by city or postal code, from which you are searching. Before searching for available First Stop outlets, we ask for your consent to the processing of your geolocation data via a pop-up window.
When you book an appointment online for a service at one of the First Stop points of sale, we establish contact between you and the First Stop point of sale of your choice. In order to satisfy our legitimate interest in directing you to your chosen First Stop point of sale, we need you to provide information about yourself. This information includes your first name, last name, email address, telephone number, type of vehicle you drive, license plate number, choice of product and/or service, date and time of your appointment. We transfer all this data to the First Stop point of sale of your choice, which needs this information in order to be able to sell you the requested products and services. In addition, it is in our interest and that of the chosen First Stop point of sale that the appointment time is respected. Therefore, we will ask for your permission to send you an SMS and/or email the day before to remind you of your appointment.
We may invite you, on our website or by other means, to give us your consent to subscribe to Bridgestone and First Stop newsletters in order to stay informed about new products, services, promotions and events. Subscribing to our newsletters requires us to process your first name, last name and e-mail address. You may withdraw your consent at any time by clicking on the unsubscribe link in each newsletter you receive from us or by contacting us via the form specified in section 7.
We also have a legitimate interest in our customers continuing to consider the First Stop brand for their next purchases. To this end, we may send our customers newsletters and advertisements by e-mail to inform them of new automotive products and services or other products and services that may be purchased from First Stop. You may object to receiving these e-mails by notifying us at the time of sale, unsubscribing at the time of online ordering, or contacting us at any time via the form specified in section 7.
Visiting our websites
This is information that associates your visit to the point of sale location page of our website with phone calls you make to one of our outlets using the phone number you obtained from our website. This information allows us to track the effectiveness of our website to potential customers who search for our products and services online before making a purchase at the point of sale. We only track your calls with your explicit consent. Call analysis only involves tracking the making of the call, the date and time of the call, and your phone number. We do not record the telephone conversation and will not use your phone number to contact you.
Customer profiling and analysis
We may build customer profiles from personal data we have processed when you purchase products and services such as your age, gender, the vehicle you drive, your geographic location, the category of tyres purchased or the level of engagement with us. Customer profiling is based on our legitimate interest in better understanding different categories of customer preferences and in offering or promoting products and services that we believe meet the interests of a specific profile. For example, we can profile customers living in a geographic area where it regularly snows as potential winter tire buyers. Customer profiles can also be established based on visitors' browsing habits. However, visitors to the website are not profiled unless they have given their consent to the placement of marketing cookies.
Archiving your purchase history
We archive your purchase history beyond the legal retention period for statistical purposes, as a processing activity compatible with processing to carry out a commercial transaction (see section 3a), using pseudonymisation techniques to prevent the archive from being able to identify you.
Supplier and dealer management
Our interactions with suppliers and dealers (hereinafter "business relationships") require us to process the personal data of natural persons designated by the business relationship to act as contact persons in the context of managing certain aspects of this relationship. This data may be requested by First Stop, or communicated by the supplier or dealer who employs these natural persons, or communicated by these natural persons themselves. In each case, we process the data on the basis of our legitimate interest in business relationships being managed by the designated key contact persons.
We will not collect any personal data that is not relevant for the purposes set out above, or that is notified to you by any other means when we ask for your consent for the processing of your personal data.
4. How long is personal data stored?
We do not store the data longer than is necessary for our purposes or, where applicable, than the duration set contractually or by law.
We store your personal data for a specific purpose:
- until you object to our use for this purpose where applicable laws give you a right to object and we do not have compelling grounds for processing that override your rights;
- until the expiry of our legitimate interest or the contract under which we process the data concerned, unless we have an ongoing legal obligation to retain the data for a longer period. For example, data relating to a commercial transaction must be kept for a period of between seven and ten years (depending on the country) for accounting and tax purposes;
- until you withdraw your consent or object to our processing based on your consent or until five years have passed since you gave your consent, whichever occurs first;
- until you decide not to renew your previously given consent, in situations where our policies allow individuals to renew their consent at regular intervals. For example, our consent-based cookies remain in place for a period of thirteen months, unless you have changed your preferences earlier;
- In the event that we process your personal data pursuant to a legal obligation, we retain the data for as long as we are subject to that legal obligation.
5. Who are the recipients of your personal data?
We will only disclose your personal data for the purposes and category of recipients described below. We will take appropriate steps to ensure that your personal data is processed, secured and transferred in accordance with applicable law.
- Our authorized personnel:
Your personal data is processed by our authorised personnel on a need-to-know basis. These personnel are bound by an obligation of confidentiality.
- Other Bridgestone Group entities:
We are part of a global organization (hereinafter the "Bridgestone Group"), consisting of several companies in Europe and other regions that all use the same integrated IT infrastructure. As part of data management, your personal data may be transferred to one or more affiliated companies of the Bridgestone group located in or outside the European Union or the United Kingdom, for data processing and storage purposes, to provide you with access to our services, to provide customer support, to make decisions regarding service improvement or content development, and for other purposes described herein.
- External recipients
We use external companies whose services involve the processing of personal data on our behalf. For example, the data we hold is stored by cloud service providers, and our direct marketing is handled by marketers. When we make an appointment on your behalf, the First Stop point of sale you have selected will receive your personal data to use for its own purposes, in order to be able to provide you with the requested products and services.
When you purchase products online, in the payment environment, depending on the payment method chosen, you must provide the name of the bank account holder, your address, IBAN, payment card number, cvv number and card expiry date. We do not store your payment card information ourselves, but we do work with a payment service provider who is authorized to store payment data and who will process payment for the products and services you purchase from First Stop. As for the sharing of your personal data with the payment service provider, its legal basis is the sales contract we conclude with you.
International transfers of personal data
Some of your personal data may be transferred to recipients located in countries outside the European Union, the European Economic Area (EEA) or the United Kingdom ("third countries").
Any transfer of personal data to countries other than those for which an adequacy decision on the level of data protection has been taken by the European Commission takes place on the basis of standard contractual clauses agreements adopted by the European Commission or other appropriate safeguards in accordance with the Governing Law. As a data subject, if you wish to obtain a copy of these guarantees, please contact us (see section 7).
6. Rights of users with regard to their personal data
You have specific legal rights in relation to the personal data we process about you. We will respect your individual rights and handle your requests appropriately.
The following list contains information about your legal rights arising from applicable data protection legislation:
- Right of access: you have the right to obtain from us information about the personal data we hold about you, including information about the categories of personal data we have in our possession or control, their purpose, where we collected it if not directly from you, and to whom it has been disclosed, if any. You can obtain a copy of the personal data we hold about you free of charge. We reserve the right to charge a reasonable fee for any additional copies requested.
- Right to rectification: you have the right to obtain from us the rectification of personal data concerning you. We make every effort to ensure that the personal data in our possession is accurate, complete, up-to-date and relevant, based on the most recent information available to us. In appropriate cases, we provide self-service web portals that allow users to view and rectify their personal data.
- Right to restriction of processing: you have the right to obtain from us the restriction of the processing of your personal data when:
- you contest the accuracy of your personal data for a period of time that allows us to verify its accuracy;
- the processing is unlawful and you request the restriction of the processing of your personal data rather than their erasure;
- we no longer need your personal data but you still need it for the establishment, exercise or defence of legal claims;
- you object to the processing while we verify whether the legitimate grounds we pursue override yours.
- Right to data portability: We will transfer your personal data to another controller at your request where such an operation is technically feasible, provided that the processing is based on your consent or necessary for the performance of a contract. Rather than receiving a copy of your personal data, you have the right to have it transmitted directly to another controller of your choice.
- Right to erasure: You have the right to obtain from us the erasure of your personal data when:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- you have the right to object to further processing of your personal data (see below) and to exercise this right by objecting to the processing;
- the personal data have been unlawfully processed; unless the processing is necessary for compliance with a legal obligation that requires processing on our part, in particular for legal data retention obligations;
- for the establishment, exercise or defence of legal claims.
- Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data, provided that the processing is based on our legitimate interests or those of a third party, or that the processing concerns the archiving of your purchase history. In such cases, we will no longer process your personal data. However, if you object to processing based on our legitimate interest, we will be allowed to continue the processing if we can demonstrate compelling legitimate grounds for the processing or if we need the data for the establishment, exercise or defence of legal claims. If you object to the processing, please specify whether you wish your personal data to be erased or to have their processing restricted by First Stop.
We will respond to your request within thirty days. However, this period may be extended for reasons relating to specific legal law or the complexity of your request.
In some situations, we may not be able to provide you with access to some or all of your personal data under legal requirements. If your access request is rejected, we will inform you of the reason for the refusal.
In some cases, we may not be able to clearly identify you based on your personal data due to the identifiers provided in your request. In such situations, where we cannot identify you as a data subject, we are unable to respond to your request to exercise your legal rights as described in this section unless you provide additional personally identifiable information.
If you wish to exercise your legal rights, please submit your request to: firstname.lastname@example.org
If you believe that the processing of your personal data infringes your legal rights, you have the right to lodge a complaint with a data protection supervisory authority, in particular in the country where your habitual residence, place of work or place of the alleged infringement is located.
Persons under the age of sixteen ("minors") are not permitted to provide us with their personal data without the consent and supervision of a parent or guardian. In the absence of such permission, we will not collect any personal data from minors. If we become aware that personal data relating to minors has been inadvertently collected, we will delete this data without undue delay.
10. Changes to this Policy
We reserve the right to change our privacy practices at our discretion and to update this policy at any time. Therefore, we invite you to consult this document regularly. The date of the last update appears at the top of this page. We will process your personal data in accordance with the policy under which it was collected, unless you allow us to treat it differently.