Horsepower Rewards Privacy Policy

This Privacy Policy (“Policy”) describes how Continental Tire the Americas, LLC (“CTA”, “our”, “us”, “we” or “controller”) uses and protects your Personal Information (as defined herein) that CTA collects, processes, or otherwise has access to when you set-up and use the www.horsepowerrewards.com (“Website” or “Service”). 

Please review Our Notice of Financial Incentive for additional information regarding the rewards program.

California Residents: Please see Supplement For California Consumers.

Acceptance of Policy

By downloading, accessing, and/or using the Website, or otherwise providing your personal information to CTA, you signify your acceptance of this Policy. If you do not agree to this Policy, do not register for an account and immediately discontinue your use of the Website.

Sources of Personal Information

In providing the Service, CTA may collect, process, transfer, or otherwise have access to various information and data, including your Personal Information.  “Personal Information” refers to any information relating to an identified or identifiable natural person or household (as applicable), and includes but is not limited to “personal data”, “personal information”, and such other substantially equivalent terms defined in applicable laws that apply to Us.

We collect information, including Personal Information, about you and how you interact with us in several ways, including:

• Information You Provide to Us Directly. We collect the information you provide to us directly.

• Information Automatically Collected or Inferred from Your Interaction with Us. We automatically collect technical information about your interactions with Us, such as the time the Website is used, the number of times the Website is accessed or used per day, the time spent in the different pages, the time the microphone and camera is used, the number of pages accessed, the number of clicks to get the solutions, and the number of attempts the camera and microphone is used to obtain a result.
• Information from Third Parties. We receive information about you and your interactions with us from third parties, including your employer, principal, coworkers and others interacting with us and/or using CTA services.

Personal Information We Collect

The types of Personal Information that CTA has collected about you during your registration and use of the Service during the preceding 12 months are:

• Identifiers, such as your name, alias, postal address, country of residence, unique personal identifier, online identifier, email address, account name, phone number, or other similar identifiers.
• Financial information, such as your bank account number, credit card number, debit card number, government-issued Tax ID, or any other financial information.
• Commercial information and preferences, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, such as your internet protocol address and information regarding your interactions with our Website. For more information on our collection of this type of information, please see Cookies and Analytics Tools below.
• Professional, employment, or education information, such as job title, business address, employment history, or other professional information.
• Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences, characteristics, or behavior.
• Customer support data, including information collected when you contact us for help with your account (including, but not limited to, name, telephone number and contact information, summary of issue(s) discussed).

• Sensitive Personal Information, including:
  • Social Security Number, Tax Identification Number, or other government-issued identification numbers.

Privacy expectations and regulations are continually changing, and we expect Our use and handling of your Personal Information will change over time to meet those changes and expectations.  If Our use of your Personal Information changes in a material way, we will separately notify you and, if necessary, obtain your consent (see Modifications section below).

How CTA Uses Your Personal Information

• To Provide the Website, Administer the Horsepower Rewards Program, Enable Interactions Between Us, and Facilitate Transactions You Request. This includes, but is not limited to, registration and administration of your account, providing you with and support in your interactions with us; diagnosing, repairing and tracking service and quality issues; facilitating an order, download, return, or exchange; providing requested information; communicating with you about your account or our data practices; installing and configuring changes and updates to the Website, programs and technologies related to interactions with us; authenticate those who interact with us; or to respond to your requests, complaints, and inquiries.

• To Provide Customer Support. CTA strives to provide quality products and services, including supporting you when you need it. To do this, we use your personal information to investigate and assist you in resolving questions or issues you have regarding CTA products and services, and provide you support or respond to you. The legal basis for the use of your data for such purposes is either the contractual obligation with you or legitimate interests.
• For Our Internal Business Purposes. We may use your Personal Information for our internal business purposes related to providing the Website, as well as other products and technologies. This includes, but is not limited to, evaluating or auditing the usage and performance of Website, programs and technologies related to interactions with us; evaluating and improving the quality of your interactions with us and the Website, programs and technologies related to interactions with us; designing new services; performing internal research for technological development and demonstration; conducting data analysis and testing; maintaining proper business records and other relevant records. The legal basis for the use of your data for such purposes is either the contractual relationship with you or our legitimate interests.
• For Legal, Safety or Security Reasons, such as to comply with legal requirements; protect our safety, our property or rights of those who interact with us, or others; investigate and respond to claims against us, our customers, our partners, and our employees; address security issues; and detect, prevent, and respond to security incidents or other malicious, deceptive, fraudulent, or illegal activity.
• In a De-identified, Anonymized or Aggregated Format.  When converted to a de-identified, anonymized, or aggregated format, this data no longer constitutes Personal Information and we may use this information for any purpose.
• For any other purposes for which you provide consent.

To Whom We Disclose Your Information

To provide the Website, we may share your Personal Information with these recipients:

• Affiliates and Subsidiaries. We may share your Personal Information within the CTA group of companies, which includes parents, corporate affiliates, subsidiaries, business units and other companies that share common ownership for the purposes described above. Such transfers to affiliates will be in accordance with CTA’s Binding Corporate Rules (“BCRs”), a copy of which is available here: CTA BCRs.

• Third party service providers.  We may disclose your Personal Information to third party service providers that support the provision and maintenance of the Website, that work on our behalf to facilitate our interactions with you or, or that otherwise support our relationship with you.  include website and data hosting providers, IT providers, operating systems and platforms, internet service providers, analytics companies, and marketing providers (e.g., we may disclose your email address to our outbound email marketing provider).  We may contract with other companies to provide certain services, including identity verification, email distribution, market research, and promotions management. We have contractual agreements with these service providers to restrict their use of your Personal Information, and we provide these companies with only the information they need to perform their services and work with them to ensure that your privacy is respected and protected.
• Professional consultants. We may disclose your Personal Information to our professional consultants who are bound by confidentiality and professional obligations, such as our accountants, lawyers, financial advisors, and audit firms.
• Vendors necessary to complete transactions you request. If we engage in a transaction, we may share Personal Information with supporting vendors such as shipping companies, payment processors, and logistics providers.
• Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes.  We may disclose your Personal Information to third parties such as law enforcement or other government agencies to comply with law or legal requirements; to enforce or apply our Terms of Use and other agreements; and to protect our rights and our property or safety of our users or third parties.
• In connection with a transaction.  If we sell some or all of our assets, merge or are acquired by another entity, including through a sale or in connection with a bankruptcy, we will disclose your Personal Information as part of that transaction.

We may also de-identify, anonymize, or aggregate your Personal Information to disclose to third parties for any purpose.

Your Rights

Please note that under applicable data protection laws and regulations you may have the following rights in connection with CTA’s processing and use of your Personal Information as a Controller:

• Right of Information. You may receive information about your ability to refuse consent and the consequences associated with such refusal. 
• Right to Notice. CTA provides this Policy, detailing how Personal Information is processed, including the third parties with which CTA has shared your Personal Information.  CTA will provided updated notice and information any time the types of Personal Information processed and/or CTA’s use and sharing of your Personal Information materially change.
• Right to Revoke Consent. You may withdraw consent at any time, and CTA will stop processing and delete your Personal Information, subject to CTA’s right to retain the data as allowed for lawful purposes, including to comply with its legal obligations and to use it exclusively on an anonymized basis. Consent must be withdrawn in writing to privacy@continental.com. See Cookies and Analytics Tools section below for additional information regarding placement of cookies and associated processing activities.
• Right of Access. You may obtain from CTA confirmation regarding whether Personal Information is being processed and, if it is, access to the Personal Information and additional information about the processing of such Personal Information.
• Right to Correction/Rectification. You may have inaccurate Personal Information corrected and have incomplete Personal Information made complete.
• Right to Deletion. You may have Personal Information deleted in certain circumstances.
• Right to Restrict Processing. You may have additional processing of Personal Information restricted and/or temporarily blocked while the sufficiency, necessity, accuracy, or legality of processing of the Personal Information is contested.
• Right to Data Portability. You may be able to receive Personal Information for the purpose of providing that Personal Information to another controller, either through you as our business customer or directly by CTA.
• Right to Object. You may object, at any time and on grounds relating to their particular situation, that processing of Personal Information is unnecessary or excessive.
• Right to complain to a Relevant Supervisory Authority. If you have a complaint about our privacy practices, you have the right to submit a complaint to a relevant supervisory authority.

You may exercise your rights as described in the Contacting Us and Exercising Your Rights section below. You may correct or update any of the Personal Information you provided to us when you registered for an account on the Website by editing your Registered User profile.

CTA may request additional information from you as necessary to allow you to exercise your rights, and we may deny your request where we have a legitimate basis to do so.

Security and Retention

We maintain reasonable security procedures and technical and organizational measures to protect your Personal Information against accidental or unlawful destruction, loss, disclosure, alteration, or use. But no security measures can be 100% effective, and we cannot guarantee the security of your information, including against unauthorized intrusions or acts by third parties.

We retain your Personal Information as long as necessary to fulfill the purposes outlined in this Policy unless we are required to do otherwise by applicable law. This includes retaining your Personal Information to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your Personal Information in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to enable easier future user onboarding, demonstrate our business practices and contractual obligations, or provide you with information about our products and services in case of interest.  For additional information regarding account inactivity, please see the Program Rules at https://horsepowerrewards.com.

In some circumstances you can ask us to delete your Personal Information. See Your Rights section above for additional information.

In some circumstances we will anonymize your Personal Information (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.

Third Party Websites

When you click on a link to any other website or location, you will leave our Website and go to another site and another entity may collect personal information from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.  If you decide to access any third party links appearing in the Website, you do so at your own risk.

Policy for Children

The Website is intended for and marketed to adults only.  We do not knowingly solicit information from or market to children under the age of 16. If you become aware of any Personal Information that we have collected from children under age 16, please contact us using the contact information provided above.

Changes to Personal Information

You may change any of the Personal Information you provide to us when you subscribe to the Website by editing your user profile. You may request deletion of your personal information, but please note that we may be required to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.

Modifications

We may modify this Policy from time to time as the Website and applicable laws change.  If we change our Policy, we will post a new statement on this website and update the effective date stated at the end of the Policy.  You are encouraged to review this Policy from time-to-time for any updates or changes. If we make any material changes, we will inform you through the Website, by sending a message to the e-mail address associated with your account, or by some other method of communication. 

Please see our https://horsepowerrewards.com for a more detailed legal explanation of our usages policies.  Changes to the Policy become effective immediately upon notice to you.  Notice may be given by posting the revised Policy on this website or by other means.  Your use of the Website after notice constitutes Your acceptance of the revised terms. 

Horsepower Rewards Financial Incentive Notice (“Notice”)

In the context of the Horsepower Rewards program (“Horsepower”), Continental Tire the Americas, LLC (“CTA”, “our”, “us” or “we”) offers loyalty benefits, rewards, and other incentives to eligible participants related to the collection, retention, or sale of Personal Information (as such term is defined in our Privacy Policy) that may be considered a “financial incentive” or “bona fide loyalty program” under applicable laws.  For additional information regard our general data collection and use practices, please review https://horsepowerrewards.com/anonymous/privacyPolicy.aspx?.

Horsepower is a reward/loyalty program by which registered and eligible Continental customers can earn rewards, accumulate points based on tire purchases, and access exclusive promotional offers, such as free products, discounts, coupons, and opportunities to participate in other promotions. To provide and administer the Horsepower, we will collect and use Personal Information, such as your name, email address, phone number, Social Security Number.  For more information on Horsepower, including rules and eligibility, please see https://horsepowerrewards.com/UserUploads/Attachments/HorsepowerProgramRules638164699231525761.pdf Our good-faith estimate of the value of your Personal Information is the value of the benefit we offer to you. We have calculated such value by using the expense related to the benefit.

Opting Out. By submitting your Personal Information and registering for Horsepower, you voluntarily opt-in to this financial incentive and all terms applicable thereto.  If you do not wish to provide your Personal Information, or if you do not agree with the terms of this Notice or the Rules, please do not register for Horsepower.

Withdrawing/Opting Out. Participation in Horsepower is always optional, and you can terminate your participation at any time as explained in the Rules.  You can also contact us at alison.bowker@conti-na.com to unsubscribe or cancel your participation in any program.  You may unsubscribe or opt-out of email communications by following the unsubscribe link and directions contained in the applicable email.

Contacting Us and Exercising Your Rights

If you have any questions about our Policy or our use of your Personal Information If you have questions regarding this Policy or if you would like to exercise any of your rights described in this Policy, please contact us at:

WEBFORM LINK

EMAIL:            privacy@continental.com

PHONE:          (833) 656-0555

You may also reach us by regular mail to Continental Tire the Americas, LLC 1830 MacMillan Park Dr. Fort Mill, SC 29707, Attn: Ali Bowker.

Requests for changes to your Personal Information and/or cancellation of your registration can be made to alison.bowker@conti-na.com.

Cookies and Analytics Tools

A cookie is a small data file that is stored on your terminal device. Cookies are used to analyze user interest in our websites and help make them more user-friendly. You may in general access our websites without cookies as well. If you, however, wish to use the full functionality of our websites in the most user-friendly manner, you should accept the cookies that enable the use of certain functions or provide convenience features. The intended purpose of the cookies we use is shown in the list that follows.

By using our websites, you consent to the use of those cookies that your browser accepts based on your browser settings. You may, however, set your browser to notify you before cookies are accepted, to accept or reject only certain cookies, or to reject all cookies. You are furthermore able to delete cookies from your storage medium at any time.  

The following cookies are currently activated*:

Permanent Cookies (Technically Necessary System Cookies)

Optional Cookies (Tracking-Cookies for Website Analysis)

Piwik Cookies (_pk_id. and _pk_ses.)

This cookie is used to analyze user behavior on our website using the web analytics open source Piwik. All collected data are analyzed anonymously.

Mouseflow Cookie (gtm.ct.mf)

This cookie is used to analyze user behavior on our website using the web analytics mouseflow. All collected data are analyzed anonymously.

You can choose not to accept these cookies in your browser settings. Please note, however, that several functions may then not be available.

Supplement For California Users

If you are a California resident, this section applies.  Pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”), in the sections above we have provided a summary of the Personal Information that we have collected from you, the sources from which we have collected the Personal Information, the business or commercial purpose for which the Personal Information was collected, and the categories of third parties with whom we share consumer Personal Information.  Under the CCPA, you may have specific rights. 

In addition to the disclosures above, this section provides supplemental information about how we process Personal Information of California residents.  We disclose all of the categories of Personal Information that we collect in the “Types of Personal Information We Collect” section to all of the categories of recipients set forth in the “To Whom We Disclose Your Information”.

We do not “sell” or “share” your Personal Information, as those terms are defined under California law.

Your Rights

California residents have certain rights, subject to legal limitations, regarding the collection, use, and sharing of Personal Information. California residents may exercise the following rights as set forth in the Contacting Us and Exercising Your Rights section above.

• Right to Know. You have the right to request information about the categories of Personal Information we have collected about you, the categories of sources from which we collected the Personal Information, the purposes for collecting the Personal Information, the categories of third parties with whom we have shared your Personal Information, and the purpose for which we shared your Personal Information (“Categories Report”). You may also request information about the specific pieces of Personal Information we have collected about you (“Specific Pieces Report”).

• Right to Delete. You have the right to request that we delete Personal Information that we have collected from you.

We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights.

Verification

In order to exercise your rights, we will need to obtain information to locate you in our records or verify your identity depending on the nature of the request. If you are submitting a request on behalf of a household, we will need to verify each member of the household in the manner set forth above. We will use commercially reasonable verification techniques, designed to balance the need to ensure we are not providing your information to someone pretending to be you, while at the same time not making it too difficult for you to exercise your rights.

Authorized Agents

You may use an authorized agent to exercise your rights on your behalf. If you are making any of the requests above through an authorized agent, we will request written authorization from you and will seek to verify you as described above or we will accept a legal Power of Attorney under the California Probate Code to the authorized agent.

Timing

We will respond to Requests to Delete and Requests to Know within 45 days, unless we need more time, in which case we will notify you and may take up to 90 days total to respond to your request.

This Version of the Policy is Effective as of October 20, 2023.