Your privacy in Automotive navigation from HERE 

The purpose of this document is to provide information on the processing of your personal data in connection with your use of the Automotive navigation system and its features (the “Service”). 

The features of the Service enable you for example to navigate from one place to another, find places and addresses on a map, interact with them and access relevant content, as well as synchronize information related to your drives to access from other screens and devices. You can share places, routes and arrival times with your friends. The Service also helps you to optimize your daily commute by learning your habits. 

This document applies to the following elements that the Service can include depending on the vehicle’s make, model and the navigation system in use: 

• - the in-vehicle navigation system, 
• - the online account which enables you to plan your route in advance and sync it with your vehicle, and  
• - the navigation or route planning mobile device application which continues to guide you outside of your vehicle.  

The Service includes experiences designed for use by a driver as well as other users of the vehicle, such as co-drivers or passengers, passengers. It is your responsibility to ensure that this information along with applicable terms is passed on to such other users. 

1. Categories of data we process 

We collect the following categories of information: 

1.1 Registration and contact details 

Some features may require the use of HERE account, for example when you want to synchronize your collections. When you register, we collect your registration credentials and settings such as country/region and language preference. You may continue to use the other features of the Service without signing in. When you are logged in with your HERE account, we will try to automatically synchronize your recent searches and your collections in association with your HERE account. 

1.2 Location Data and Place Information 

Our Service makes use of information about your actual location (“Location Data”) and information about places (“Place Information”). Location Data reveals where you currently are or where you have been. Location Data is based on available positioning methods, such as GPS. In many device models the user interface of the Service identifies the use of positioning with an icon. Place Information is general information pertaining to particular geographical location (e.g. city or a location of a restaurant) that you may have provided to us, for example your collections or saved destinations. 

Unless otherwise stated, we use random identifiers in connection with your Location Data that do not identify you personally. 

When you start to use the Service, the applicable Service activates your selected positioning methods to retrieve your current location. The Service may send your Location Data to HERE when you use location enabled features of the Service online, such as ask information about nearby services or offerings, use search features, as well as when the Service asks for new maps for new areas you have navigated into. As further described below, Location Data may be collected when you use the traffic feature for service improvement purposes without identifying you personally.  

Place Information may be sent to HERE for example when you synchronize your favorites across devices. 

1.3 Traffic Improvement 

Whenever you use the Service while having traffic features enabled, the Service sends, in regular intervals, your current location, speed, direction and timestamp to us to provide you and other users of the Service with better traffic service such as detect traffic jams, traffic patterns, changed road conditions and other such conditions as well as to identify new routes on the map. This information is analyzed to distinguish independent routes and traffic patterns and contains a changing identifier, which is persistent only for the duration of the route. This information is sent to us when you use the Service online. In case you are using the Service offline, we may collect this information locally on device and it may be sent to us on your next connection. 

1.4 My commute 

You may activate My Commute feature in the Service to let the Service learn your daily commutes and help you optimize your travel. While learning your daily commutes, the Service can start recommending optimal times for travel based on foreseen traffic situation. All the information collected by the My Commute feature, which includes information about the routes you’ve driven and places related to your commute remains only in the vehicle and is never sent outside the vehicle. Information is stored protected against unauthorized use.    

You may manage your learned routes and preferences and you may turn the My Commute feature on and off via settings of the Service. 

1.5 Technical information and your transactions 

When you use the Service online, certain technical information such as the details of the application version, service permissions, vehicle identification number, internet protocol address, time zone, technical details of your device and connection as well as your transactions with HERE may be automatically collected by HERE. 

2. Purposes and legal bases of the processing 

We process your data   to provide the Service to you, manage our transactions and communications with you, meet information security requirements, and to improve our products and services. Specific uses of personal data and the legal grounds we rely on for these are: 

2.1. Provision of the Services  

The information collected by the Service is utilized to provide you with the service, manage our transactions and communications with you and ensure ongoing compliance with information security requirements.  

When you make use of optional features, we may also use the information to provide you with improved search and recommendations to better assist you to find a place you may like. Optional features can be deactivated at any time.  

Applicable legal bases are: 

• - the performance of a contract with you under the Service Terms, 
• - our legitimate interest in the provision of the Service with respect to passengers and other users including individuals with whom you elect to share your data such as estimated time of arrival, 
• - your consent that you provide when downloading our mobile application, granting permission to access information on your device or when you ask us to share your data. You may revoke your consent by changing your settings at any time in Settings. Doing so will bar us from further processing of your personal data based on your consent but will not impact the lawfulness of processing based on your consent before it was withdrawn.  

If you do not provide your data, such as by forgoing an account registration, we are not able to provide the features of the Service depending on such data (i.e. syncing of destinations across devices). 

2.2. Developing and improving our products and services  

We process your data to provide you and other users with better Service such as improving search and recommendations, better assisting you to find a place you may like or detect new routes on the map. 

For this purpose, we use the traffic information collected from your drives in an anonymous manner. We do not associate your Location Data or Places Information with your other personally identifiable information, such as an InControl Navigation Account, unless you have asked us to do so. For example, we do not combine your Place Information such as favorite, recent or shared destinations with your Location Data. We implement appropriate technical and organizational measures to prevent associating your Location Data with other personally identifiable information without your permission. 

Applicable legal bases are: 

• - our legitimate interest in the development and improvement of our services, ensuring that your rights are not undermined by anonymizing data and implementing other appropriate safeguards.  

3. Processing and retention period 

We endeavor to only collect personal data that are necessary for the purposes for which they are collected, and to retain such data for no longer than is necessary for such purposes. The length of time personal data is retained, and criteria for determining that time, are dependent on the nature of the personal data and the purpose for which it was provided. For example, for your personal data related to managing your account (such as name, email address, and account content and preferences) are maintained for as long as they are retained by you within your account. Other data, such as records of your activity within the application, are typically maintained only for a short period before being anonymized. You may contact the HERE Privacy Office at privacy@HERE.com to obtain additional information about retention of your personal data. 

4. Do we share your information? 

Your Location Data will not be shared with other service providers or advertisers without your permission. 

In case you have an InControl Navigation Account, the Service may allow you to share your Location Data or Places Data. For example, if you choose to share your estimated time of arrival with selected individuals, you can do so either via SMS or email. We will facilitate the sharing interaction by collecting the list of recipients you have specified and by sending notification messages to the recipients of your choice. 

The Service may also include content from and links to third party sites and services. 

We may share your personal data: 

• - with your consent; 
• - with HERE companies and authorized third party service providers, who process personal data on our behalf; 
• - in exceptional cases with attorneys and advisors to protect our rights or property in court, arbitration or administrative proceedings; and 
• - where there is a legal requirement to do so. 

5. Transborder transfers of personal data  

The Service may be provided using resources and servers located in various countries around the world. Therefore, your personal data may be transferred across international borders outside the country where you use our services, including to countries outside the European Economic Area (EEA) that do not have laws providing specific protection for personal data or that have different legal rules on data protection, for example, the United States of America. In such cases we ensure that there is a legal basis for such a transfer and that adequate protection for your personal data is provided as required by applicable law, for example, by relying on an adequacy decision and/or using standard contractual clauses approved by the European Commission or relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures.  

You may contact the HERE Privacy Office at privacy@HERE.com to obtain additional information about the safeguards we take in connection with these transfers. A copy of the unchangeable Standard Contractual Clauses can be accessed at https://commission.europa.eu/publications/standard-contractual-clauses-i...

6. Your choices 

The Service offers a variety of choices to allow you to control how your Location Data and other information are collected. 

You may configure individual features or feature sets of the Service to be used in offline or online mode. No Location Data or other information is sent to HERE if you only use the Service in offline mode. Note that your vehicle may nevertheless have stored information which may be sent to HERE once you establish an online connection, as defined earlier in this document. 

You may choose the level at which you participate in the development of HERE’s products and services. You may disable the collection of Location Data for traffic improvement purposes by turning off the traffic service. Note that then you’re also not able to benefit from the traffic service. 

You may choose to create a profile either locally in the vehicle or an InControl Navigation Account with features which help you store and synchronize your information outside the vehicle context, such as with your mobile and other devices. You may choose to enable and disable the synchronization or your favourites as well as your most recent location of your car. 

If you have enabled the synchronization of the location of your parked car, the Service will automatically, or upon request, send the parked car location in association with each and every active InControl Navigation Account on the vehicle. This allows you to easily share the location of your car for example with other family members. If you don’t want to share the location of your car with other account holders, please make sure the other users are in a logged out state while you drive. 

You may delete a local profile or the application from your mobile device, which will delete all locally stored information associated to your profile, such as recent destinations and recent searches. Deleting a local profile from the vehicle or the application from your mobile device will not delete any InControl Navigation Account you may have created. 

You may manage account data, remove or terminate your InControl Navigation Account in the setting of your in-vehicle system or your online InControl Navigation Account. If you remove your InControl Navigation Account from the vehicle, it remains active for your future use. 

7. Your data subject rights 

You have the following rights with respect to your personal data: 

• - to know what personal data we hold about you, and to access it, 
• - to have incomplete, incorrect, unnecessary or outdated personal data deleted or updated, 
• -  to request that your personal data be deleted,  
• - to revoke a previously granted consent to the processing of your data; 
• - to obtain a copy of your data in a machine-readable format, 
• - to object to or restrict processing in certain circumstances, such as where you believe the data is inaccurate or the processing activity is unlawful. 

If you are located in a European Union member state or within the European Economic Area, you have the right to lodge a complaint about our data collection and processing activities with the supervisory authority concerned. 

You may exercise your rights by contacting us via email at: privacy@here.com or through our request submission webform at https://legal.here.com/en-gb/here-data-subject-request

In some cases, especially if you wish us to delete or stop processing your personal data, this may also mean that we may not be able to continue to provide the Services to you. Applicable data protection law may provide certain restrictions on the extent to which these rights may be exercised. If a restriction applies, we will respond to your request with an explanation of what action will be taken, to the extent required under applicable data protection law. 

8. Controller of your Personal Data 

HERE Global B.V. of Kennedyplein 222 -226, 5611 ZT Eindhoven, Netherlands is the controller of your personal data. 

9. Other information 

We advise you to use appropriate consideration when you name your favourite places. For example, if you do not want all the users of the Service to know the location of your home, do not name the location of your home “home” and share it with all users. 

Please let us know if you encounter any content that you find inappropriate in nature by reporting through the provided channels. For more information about our privacy practices, check our privacy policy. For information concerning the service, check our support pages. 

For more information about privacy at HERE as well as information about California residents, please visit our Privacy Policy at: https://legal.here.com/us-en/privacy 

You may contact us through our customer care or our Data Protection Officer through following contact details: 

HERE Global B.V  
c/o Privacy 
Kennedyplein 222-226 

5611 ZT Eindhoven 
Netherlands 

Email: privacy@here.com