Your Privacy while participating in optional SDK improvement

HERE’s Privacy Policy explains how your personal data is processed in context of HERE products and services. The following policy supplement provides additional details regarding your use of an application provided by a party other than HERE which has integrated an SDK from HERE that permits you to opt in to providing certain information from your use of that particular application (collectively referred to as the “SDK data collection”). “We”, “us”, and “our” refers to HERE.

What is HERE’s involvement?

HERE makes available certain software development kits, or “SDKs”, which consist of libraries of computer code that independent developers can integrate into their applications. The HERE SDKs enable developers to better use HERE services, or to add location-aware features into their applications. This supplement addresses optional data collection activities that occur where you have agreed to help improve the HERE SDKs and services. Information which is sent to HERE as a necessary part of providing the HERE services is addressed in the general HERE Privacy Policy.    

Please note that we have no control over what information is directly collected or shared by the application developer who has implemented a HERE SDK. You should review the application’s privacy policy for information about the developer’s privacy practices.

What information do we collect?

The SDK data collection may collect the following information about your device, and your use of HERE services on the application making use of such HERE services. Additional details regarding the SDK data collection may be provided as part of a notice embedded within the application.

Positioning and location information

If the application you are using makes use of HERE-provided traffic or positioning services, including Wi-Fi or other network-based positioning methods, the SDK data collection involves collection of any or all of the following with HERE: Location Data, speed, direction and timestamp; number of satellites used in positioning; parameters of nearby mobile network towers; parameters of nearby Wi-Fi routers and/or Bluetooth® beacons. With your consent, this information is sent to us on regular basis, after which it is deleted from your device. This information may also be coupled with a short-lived, at a maximum 15 minutes, session identifier, which doesn’t relate to you, your device or the application you’re using. We do not use this data to identify you personally.

Road observations

If the application you are using makes use of HERE-provided image recognition services, the SDK data collection involves collection of details regarding instances where observed road features, such as speed limit signs, do not match the information shown on the map. With your consent, this information is sent to us when you use the Service online, after which it is deleted from your device. This information does not identify you personally, and we only retain anonymous information about the observed road features.

How we use the information we have collected?

Improvement of products and services

We use the collected information to improve and enrich our SDKs, maps and location services. The collected information helps us focus our improvement efforts to things that are most relevant to our consumers and to avoid error situations in the future. For these purposes, we may combine information collected by the SDK data collection with other data we may have. Even when combined with other information, we do not use this data to identify you personally or even attempt to discover your identity.

How do we collect the information?

The SDK data collection uses software that is integrated to the applications and services in the device to collect and send information to HERE. Information sent consists of only a few kilobytes per instance.

What are our information sharing practices?

We do not share the information collected by the SDK data collection with independent third parties, unless otherwise explained in our privacy policies. However, information collected related to a particular third party feature may be shared with the provider of that application or feature in aggregated non-identifiable form.

What safeguards are in place?

The information stored inside the device by the SDK data collection is protected against unauthorized access and use. The SDK data collection uses secured protocols to send the information from the device to our servers. When the information is sent, it is deleted at the same time from the device storage. If you opt-out from the SDK data collection, the SDK data collection no longer collects information. However, any unsent information that was collected before you opted out will be sent together with your opt-out instruction.

What is our legal basis for processing your Personal Data?

Participation to the SDK data collection is voluntary and based on your consent. You may revoke your consent by changing your settings at any time in your application menu or 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.

For information about how to revoke your consent or report issues, see “Your choices” below.

How long do we retain Personal Data?

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. Where collected, the 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.

Your choices

Your participation in the SDK data collection is voluntary. You may choose to turn the SDK data collection on and off at any time from the settings of the device, application or service. You may find this option under the application’s menu. If you have consented once to the HERE SDK data collection but cannot find the means to opt-out, please let us know of such circumstance by contacting us a privacy@here.com and state which application you have been using so that we can investigate.

If you want to exercise your privacy rights relating to the SDK data collection, you may contact HERE via the methods described in our privacy policy, and your request will be acted upon according to law and the privacy policies applicable to SDK data collection.

What are your rights?

As explained in more detail in our privacy policy, you have the right to know what personal data we hold about you, and to access it. You have a right to have incomplete, incorrect, unnecessary or outdated personal data deleted or updated. You have the right to request that your personal data be erased, and to obtain a copy of your data in a machine-readable format. You have the right to object to or restrict processing in certain circumstances, such as where you believe the data is inaccurate or the processing activity is unlawful. Additional rights may be available in your jurisdiction. You should review the HERE privacy policy applicable to you for further information about your privacy rights.

Who is the controller of your Personal Data?

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

Other information

You may contact HERE or our Data Protection Officer, Emmanuel Salami, through the following contact details:

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

5611 ZT Eindhoven
Netherlands

Email: privacy@here.com