PRIVACY POLICY

Privacy Policy

Michelin ROH Co., Ltd. (“Michelin”, “we”, “us”) is committed to protecting your personal information and to adopting a clear and transparent approach regarding the information we collect and how we use it. This policy explains how we process the personal information we collect, or that you provide to us, when you use our recruitment website or our digital recruitment services. 

Please read this policy carefully to understand our approach and practices regarding your personal information and how we will process it. 

This policy is governed by the Personal Data Protection Act B.E. 2562 (2019) (“PDPA”) of Thailand. 

Contents

  1. Who we are and how to contact us

  2. Websites covered by this personal data policy

  3. About our Personal Data Protection Service

  4. Other policies and information we recommend you consult

    4.1 Supplementary personal data policies

    4.2 Our cookie policy

    4.3 Linked platforms

  5. The information we may collect about you

    5.1 Purposes, categories of data, legal bases and retention periods

    5.2 Voluntary information

    5.3 Statistical information

    5.4 Minors and personal information

    5.5 Candidate selection assistance tool

  6. Information we collect about you from other sources

  7. Where we store your personal information

  8. Sharing your personal information

    8.1 Within the Michelin Group

    8.2 With service providers (processors)

    8.3 With third parties

  9. International transfers of personal data

  10. How long we retain your personal information

  11. Your rights under data protection law

    11.1 The right to be informed

    11.2 The right of access

    11.3 The right to rectification

    11.4 The right to erasure

    11.5 The right to restrict processing

    11.6 The right to object

    11.7 The right to withdraw consent

    11.8 Further information about your rights

  12. Remedies available to you if you are not satisfied

  13. About data security

  14. Changes to our personal data policy

1. Who we are and how to contact us

The data controller for your personal data in connection with the recruitment website and related services is:

Michelin ROH Co., Ltd.

33/4 The Nine Towers Grand Rama 9 Building A, Rama 9 Road, Huai Khwang,

Huai Khwang, Bangkok 10310, Thailand

If you have any questions about this privacy policy or how we process your personal data, you may contact us or our Data Protection Officer (DPO) using the details below:

  • Data Protection Officer (DPO)

    Michelin ROH Co., Ltd.

    33/4 The Nine Towers Grand Rama 9 Building A, Rama 9 Road, Huai Khwang, Huai Khwang, Bangkok 10310, Thailand

  • Email: dpo-e2a@michelin.com

  • MICHELIN hotline: (+66) 02 700 3993 (Mon–Fri: 9.00 – 17.00)

2. Websites covered by this personal data policy

The information set out in this policy applies to the Michelin ROH Co., Ltd. recruitment website and the video platforms we use. To find out which personal data is processed as part of recruitment management, please refer to Section 5 below.

3. About our Personal Data Protection Service

Although all Michelin ROH Co., Ltd. employees are committed to protecting and respecting your privacy, Michelin has DPO responsible for all matters relating to personal data within the Michelin Group.

For E2A (Asia Pacific) related matters, you can contact the Michelin Data Protection Officer at dpo-e2a@michelin.com . You may also contact the Michelin Group Personal Data Protection Service at privacy.fr@michelin.com

4. Other policies and information we recommend you consult

This personal data policy contains all the information you need about how we collect and use your personal information on our recruitment website. However, we recommend that you also consult the more specific policies listed below.

4.1 Supplementary personal data policies

This document is our personal data policy with respect to the use of the recruitment website and the digital products and services offered by Michelin ROH Co., Ltd. and the Michelin Group. Additional information may be found in separate personal data policies specific to certain digital products and services. Please consult those policies when you register for or subscribe to those products or services.

4.2 Our cookie policy

When you use our website or other digital products and services we provide, information may be collected via cookies to distinguish you from other users of our website and other digital products and services. We have a separate cookie policy that explains our use of cookies and why we use them. We encourage you to check our cookie policy.

4.3 Linked platforms

Our site may contain links to and from the websites and digital platforms of our partner networks, advertisers, affiliates and social networks. If you follow a link to any of those websites, please note that they have their own personal data policies and we cannot be held responsible for those policies. Please consult those policies before providing personal information to those websites.

5. The information we may collect about you

This section sets out:

  • How we collect your personal information

  • The categories of data we collect

  • How we intend to use the information we collect

  • The legal basis on which we will rely to process the information collected

  • The retention period for the information collected

  • The specific types of data

If you wish to apply for one of our job vacancies or if you wish to join our talent pool, you must create an account and then apply.

5.1 Purposes, categories of data, legal bases and retention periods

Purpose of processing 

Type of data 

Legal basis for processing 

Retention period 

Management of the recruitment process – creation and management of a candidate account 

Account data: your email address and your password. 

Our legitimate interest in managing recruitment and providing you with an account to submit and track applications. 

Account data are retained for the period necessary to manage your application and/or until your account is deactivated, subject to applicable legal requirements. 

Selection of profiles suitable for the position, organization of exchanges, interviews (including video interviews) and tests 

Application data, including: your identification details; information relating to your professional life (education, experience, languages, CV, cover letter, candidate profile from social networks such as LinkedIn if you shared it, etc.); your training and diplomas; your financial and economic information (where relevant); recordings of deferred (pre‑recorded) interviews; and any comments. 

Pre‑contractual measures at your request (steps taken prior to entering into a potential employment contract) and, where applicable, our legitimate interest in assessing and managing applications. 

Application data are generally retained for 5 years after the end of the recruitment process (i.e. last contact with the candidate) for evidentiary purposes and to protect against potential claims (e.g. discrimination claims), unless a different period is required under PDPA or other applicable laws.  In the event of hiring, your data will be retained in accordance with applicable employment and labor laws. Recordings of deferred (pre-recorded) interviews are retained for 3 months.

Validation of your professional experience with your former employers 

Identification data, professional data, recommendations or references from former employers. 

Our legitimate interest in verifying the accuracy and relevance of the information provided and assessing your suitability for a position. 

Application data, including reference information, are generally retained for 5 years after the end of the recruitment process (last contact with the candidate), unless a different period is required under PDPA or local law.   In the event of hiring, your data will be retained in accordance with labor law upon your employment contract.

Promoting job vacancies within the Michelin Group – ensuring the visibility of your candidate profile by Michelin recruitment services in all countries and contacting you if a position matching your application becomes available. 

Application data, including: your identification details and information relating to your professional life (education, experience, languages, CV, cover letter, training and diplomas, social network profile such as LinkedIn if you shared it); financial and economic information (where relevant); and any comments. 

Pre‑contractual measures at your request (to consider you for roles) and our legitimate interest in building and maintaining a talent pool. In some cases, we may rely on your consent (for example, where required by PDPA for certain processing). 

Application data used for talent‑pool purposes are generally retained for up to 5 years after the last contact.   We may contact you within 2 years from the last contact if you were not selected, unless you withdraw your consent or object earlier.

Organizing your integration within the Michelin Group once selected, including discussing the terms of your employment, establishing your employment contract, and creating your personnel file as a new Group employee. 

Identification data, professional data, banking and financial information (for payroll and benefits). 

Pre-contractual measures at your request and, once hired, performance of the employment contract, as well as compliance with legal obligations (e.g. labor, social security, and tax laws). 

Your data will be retained in accordance with applicable labor laws in the country of employment and the terms of your employment contract. 

5.2 Voluntary information 

When you provide information to us (for example, the details described above), we may, in some cases, ask you for additional information. Such information will be clearly presented as optional (not mandatory) and may be used to help us better understand our candidates and to personalize our services. 

5.3 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 will not, in themselves, reveal your identity. For example, we may aggregate usage and device data to calculate the percentage of users of our website who access a specific feature. Aggregated Data are used for our internal purposes only. 

5.4 Minors and personal information 

Our recruitment website is not intended for minors, and we do not knowingly collect information relating to minors. If we become aware that we hold any information concerning a minor in violation of the PDPA or applicable law, we will take all measures necessary to comply with legal requirements, including deleting such information where required. 

If you learn that your minor child has provided us with personal information without your consent, please contact us as soon as possible so that we can take appropriate steps. 

5.5 Candidate selection assistance tool 

We use a solution provided by a third‑party supplier to help identify relevant candidates. This allows us to analyze your application and the match between your profile and the job you applied for. The purpose is to assist recruiters in identifying relevant candidates. 

The use of this tool is not intended to make fully automated individual decisions. It is a support tool for recruiters in the candidate selection process, and human decision-making remains central. 

6. Information we collect about you from other sources

To enable us to provide our services, we may receive personal information about you from other sources, including: 

Indirect collection from providers or partners: We may obtain data indirectly when we retrieve it from service providers or partners. For example, data produced by your responses when using tools supplied by our providers (such as questionnaires used to assess the suitability of your application), or when we analyze your activity on professional social networks such as LinkedIn. 

Server log and device information: We may collect information from our web server logs, for example details about your computer such as your IP address, operating system, or browser type. We may also collect information about searches you perform on our website and your interaction with communications we send you (for example, when you open emails). These are “usage and device data”. We use this information for system administration and to analyze how our websites and digital platforms are used, in order to provide the best online infrastructure for your digital activities. 

The legal basis for this processing is our legitimate interest in monitoring and improving our website, products and services, and in ensuring the security and proper functioning of our systems. 

As noted above, we collect information about how you use our website and our digital products and services by means of cookies or similar technologies stored on your device. Cookies contain information that is transferred to the hard drive of your computer, mobile phone or tablet. They enable us to improve our websites and provide you with a higher‑quality, more personalized service. Please consult our cookie policy for further details. 

The legal basis for this processing is your consent (where required by PDPA) or, where applicable, our legitimate interest in monitoring and improving our website, products and services. 

Our website may enable you to share information with and communicate with us via third‑party social networks such as Facebook or Twitter. We may collect information from our social media pages, including likes, shares and tweets, and information contained on social network pages. We do not control the privacy of the information you provide on social networks; the privacy policies of those social networks will apply when you use their services. 

7. Where we store your personal information

The personal data that we collect from you may be stored and processed on secure servers located in countries where Michelin Group entities or our service providers operate, including in the Asia-Pacific region (e.g. Thailand, Vietnam, Australia, Indonesia) and/or within the European Economic Area (EEA). 

As part of a global organization, your personal data may be shared within the Michelin Group. Such intra-group transfers are protected by the Michelin Group’s Binding Corporate Rules (BCR), which provide an adequate level of protection for personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR). 

Where your personal data are transferred to third parties or to countries outside Thailand or the EEA, we ensure that appropriate safeguards are in place in accordance with applicable data protection laws. These safeguards may include: 

  • the use of standard contractual clauses or equivalent transfer mechanisms; 

  • transfers to countries recognized as providing an adequate level of data protection; or 

  • reliance on applicable legal exemptions (e.g. where the transfer is necessary for the performance of a contract or for recruitment purposes). 

Where personal data are transferred outside Thailand, we will ensure that such transfers comply with the Thai Personal Data Protection Act (PDPA), including by implementing appropriate safeguards or relying on applicable exemptions. 

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, loss, or misuse. However, please note that the transmission of information via the Internet is not completely secure. While we strive to protect your personal data, any transmission is at your own risk. 

8. Sharing your personal information

Your personal data will only be disclosed to persons who need to know that information to carry out their duties, and only as permitted by the PDPA. 

We may share your personal data as follows: 

8.1 Within the Michelin Group 

We may disclose your personal information to other Michelin Group companies. For example, our parent company and other affiliates, to the extent necessary for the recruitment and HR purposes described in this policy and in compliance with applicable data protection laws. 

8.2 With service providers (processors) 

Michelin ROH Co., Ltd. may share your personal data with service providers engaged by the Michelin Group to process your request or to provide services, including IT and system administration services such as hosting, email services, recruitment platforms and alert management. 

These service providers are contractually required to ensure the confidentiality and security of the personal data they receive and to process your personal data only on our instructions and in compliance with the PDPA. 

8.3 With third parties 

Legal and contractual requirements: We may disclose or share your personal information if we are required to do so by law, regulation or court order, or in order to enforce or apply our terms of use or any other contract, or to protect our rights, property or the safety of the Michelin Group, its customers or others. Where necessary, we may disclose your information to external advisers (for example, lawyers), who will be bound by confidentiality obligations. 

Advertising and profiling (cookies): With your consent, third parties may collect information about you on our website, products or services via cookies or similar technologies for purposes such as delivering personalized advertising or carrying out profiling. Such processing is governed by our cookie policy and will comply with PDPA consent requirements. 

9. International transfers of personal data

Michelin is an international group with databases in the countries where it operates. Where required by applicable laws and/or where permitted under the PDPA, Michelin may transfer your personal data within the Michelin Group so that your application can be reviewed more broadly by relevant staff of other Michelin Group companies, and not only by Michelin ROH Co., Ltd. 

For intra-group transfers to and from the European Economic Area (EEA) and other jurisdictions, Michelin has adopted Binding Corporate Rules (BCRs) and other internal rules governing the transfer of personal data, which ensure an adequate level of protection in accordance with applicable data protection laws. 

For transfers to and from Thailand, we will comply with the PDPA requirements on cross-border data transfers, including the implementation of appropriate safeguards or reliance on applicable exemptions, where necessary. 

10. How long we retain your personal information

By default, we will not keep your personal information for longer than is necessary for the purposes for which it was collected, including to satisfy any legal, accounting or reporting requirements. 

For more specific information about how long we retain your personal information, please refer to the retention information in Section 5 above. 

When determining the appropriate retention period for personal data, we take into account: 

  • 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 by other means; and 

  • applicable legal and regulatory requirements in Thailand and other relevant jurisdictions. 

In certain circumstances, you may ask us to delete your data, please see your right to erasure in Section 11 below. 

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 that case, we may use such information indefinitely without further notice to you. 

11. Your rights under data protection law

Under the PDPA and other applicable data protection laws, you may have certain rights in relation to the processing of your personal data. These may include: 

  • The right to be informed 

  • The right of access 

  • The right to rectification 

  • The right to erasure 

  • The right to restrict processing 

  • The right to object 

  • The right to withdraw consent (where processing is based on consent) 

Details of some of these rights are set out below.

11.1 The right to be informed 

You have the right to be informed about how we collect and process your personal information, including who we are, how we use your personal information and your rights in relation to your personal information. This information is provided in this privacy policy in accordance with applicable data protection laws. 

11.2 The right of access 

You have the right to request access to the personal information we hold about you. We can confirm whether your information is being processed and provide you with a copy of your personal information, subject to any legal restrictions or exemptions. 

11.3 The right to rectification 

If your personal information is inaccurate or incomplete, you are entitled to have it corrected and updated. If we have disclosed your information to third parties, we will, where reasonably possible, inform them of any updates you have provided to us. 

You may update the personal information we hold about you by contacting us using the contact methods set out in Section 1 of this policy. 

11.4 The right to erasure 

You have the right to request the deletion or removal of your personal information where there is no lawful basis for us to continue processing it (for example, where the information is no longer necessary for the purpose for which it was originally collected or processed, or where you have withdrawn your consent and we have no other legal basis to process it). 

In certain limited circumstances the right to erasure may not apply (for example, where we need to retain the data to comply with a legal obligation or to establish, exercise or defend legal claims). If you would like to know more, please contact us. 

11.5 The right to restrict processing 

You have the right to request that we restrict the processing of your personal information (for example, while we verify its accuracy or the basis on which we process it). During this period, we will limit processing to storage only, except where further processing is permitted by law. 

11.6 The right to object 

You have the right to object to certain types of processing, including processing based on our legitimate interests and for direct marketing purposes. You can ask us not to process your personal information for the purpose of sending you information about job offers or marketing communications, where applicable. 

You may exercise this right at any time by contacting us. 

11.7 The right to withdraw consent 

Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal but may affect our ability to continue certain services (for example, keeping you in our talent pool). 

11.8 Further information about your rights 

For further information about your rights under the PDPA, or if you believe your rights have been infringed, you may contact the Office of the Personal Data Protection Committee (PDPC): 

Office of the Personal Data Protection Committee (PDPC) 

  • Call: (+66) 02 111 8800 

  • Email: saraban@pdpc.or.th 

  • Address: 120 Moo 3, Chaeng Watthana Road, Thung Song Hong, Lak Si, Bangkok 10210, Thailand 

12. Remedies available to you if you are not satisfied

We are committed to protecting and respecting your privacy. However, if you are not satisfied with the way we collect or process your personal data, or if you wish to obtain further information about your rights, you may contact us using the contact details set out in Section 1 (Who we are and how to contact us). 

We will do our best to resolve any issue you may encounter and to respond to your request as promptly as possible. 

If, after contacting us, you believe that your rights under the Thailand Personal Data Protection Act B.E. 2562 (2019) (“PDPA”) are not being respected, or that our personal data processing is not compliant with the PDPA, you may lodge a complaint with the Office of the Personal Data Protection Committee (PDPC) using the following contact details: 

Office of the Personal Data Protection Committee (PDPC) 

  • Call: (+66) 02 111 8800 

  • Email: saraban@pdpc.or.th 

  • Address: The Office of the Personal Data Protection Committee, PDPC 

    120 Moo 3, Chaeng Watthana Road, Thung Song Hong, Lak Si, Bangkok 10210, Thailand 

13. About data security

Michelin ROH Co., Ltd. has implemented measures to protect the confidentiality, security and integrity of your personal data. Access to personal data is restricted to employees and service providers who need to know that information and who have been trained to comply with privacy and security rules. 

Michelin ROH Co., Ltd. is committed to ensuring that your personal data are not altered or damaged and that unauthorized third parties do not have access to them. 

14. Changes to our personal data policy

We may update this policy from time to time. Any future changes to this policy will be published on this page. If you have an online account with us, we may notify you of any changes by email or via your account the next time you sign in, where appropriate. 

Date: April 2026