Valence Application Privacy Supplement
Your privacy in the HERE Valence driver application
The HERE Externals Privacy Policy available at https://legal.here.com/en-gb/here-externals-privacy-policy explains how your personal data is processed in context of your engagement with HERE as an independent contractor. If you are a HERE employee, the HERE Employment Privacy Policy available in the House of Policies on the HERE Intranet applies. Any additional supplements related to local privacy requirements (such as the notice applicable to California residents which is available at the end of the above-referenced privacy policies) will also continue to apply.
The following policy supplement provides additional details regarding your use of the Valence mobile application provided by HERE for you to participate as a driver (the “Valence Application”). The purpose of the Valence Application is to facilitate seamless data collection for HERE True Car drivers. “We”, “us”, and “our” in context of this supplement refers to HERE, who provides the mobile application to you as the driver.
With respect to personal data collected by us through the Valence Application from you, HERE Global, B.V. is an independent controller and to the extent your direct employer receives any information collected through the Valence Application, your direct employer is an independent data controller. The term “personal data”, as used in this privacy notice, means any information relating to you where (i) you are identified (e.g. your name, phone number, etc.); or (ii) where you could be reasonably identified (e.g. by reference to device IDs, online identification numbers or persistent cookie identifier etc.).
Please understand that the features of the Valence Application may depend on how you use the Valence Application and what your assigned job duties are.
HERE operates the HERE True Car program to enable direct collection of street level imagery, LIDAR, GPS trajectories, and similar information to support creation and improvement of its mapping and location data products. Typically HERE True vehicle drivers are independent contractors, but in some cases HERE employees may also use the Valence Application.
What information do we collect?
The Valence Application may collect the following information about your device, and your use of the Valence Application. Additional details regarding the data collection may be provided as part of a notice embedded within the Valence Application.
Driver identity
Use of the Valence Application requires the driver to enter their name, or other identifier assigned to the driver . This is to identify the driver currently using the Valence Application, and will be recorded in connection with the collected GPS trace data. Drive assignments are allocated based on HERE True vehicle IDs rather than driver identity.
Location data and place information
The Valence Application makes use of information about your actual location (“Location Data”). Location Data is based on available positioning methods, such as Assisted GPS in the device, as well as location data derived from the HERE True equipment. In many device models the user interface of the Valence Application identifies the use of positioning with an icon. When you start to use the Valence Application, the Valence Application activates your selected positioning methods to retrieve your current location.
Because the purpose of the Valence Application is to facilitate collection of HERE True data and manage and record the driving activity you were engaged with HERE to perform, Location Data will be linked to you directly. Location Data detailing routes driven will be maintained in the application for up to one day, after which it will be transferred to HERE and removed from the application .
In addition to recording routes driven, the Valence Application may send your Location Data to HERE when you use location enabled features of the Valence Application online, such as planning and navigating your route. The HERE True Cars are also separately equipped with data collection equipment which is not reported through the Valence Application.
Information about application usage
Anonymized information regarding application use, such as event logs, is sent to us when you use the Valence Application online, after which it is deleted from your device. We do not use this data to identify you personally.
Techincal information and your transactions
When you use the Valence Application online, certain technical information such as the type of your mobile device, unique device or network service provider identifiers, internet protocol address, time zone, technical details of your client as well as your transactions with HERE may be automatically collected by HERE.
How do we use the information we have collected?
Operation and development of the Valence application
The information collected by the Valence Application is used to provide the Valence Application, administer the HERE True Car program, personnel and program management, to develop our products and services, and other purposes as described in the applicable privacy policy referenced above.
Improvement of products and services
We use the collected information to improve and enrich our products and services. We may also use the information collected to develop new products and services. For these purposes, we may combine information collected by the Valence Application with other data we may already have.
What are our information sharing practices?
We may share information collected via the Valence Application with your direct employer. This is in order for HERE and your direct employer to appropriately manage your engagement with HERE.
As explained in more detail in the applicable privacy policy referenced above, we may also share your personal data:
- with your consent;
- with HERE companies and authorized third parties, who process personal data on our behalf;
- where there is a legal requirement to do so.
The information collected by the Valence Application is protected against unauthorized access and use. The Valence Application uses secured protocols to send the information from the application to our servers.
What is our legal basis for processing your Personal Data?
We process your personal data to facilitate performance of the contract under which you are engaged with HERE, either directly or via your direct employer.
HERE’s legal obligations and legitimate interests
As described in the applicable privacy policy referenced above, under some circumstances HERE will process your personal data pursuant to its own legal obligations and legitimate interests in operating its business, including conducting internal administrative activities and ensuring network and information security. HERE’s legal obligations may include matters related to employment administration, compliance with local laws related to HERE True drive activities, and other matters as provided for in applicable laws.
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.
As explained in more detail in the applicable privacy policy referenced above, 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.
You may contact our Data Protection Officer through the following contact details:
HERE Global B.V
c/o Privacy
Kennedyplein 222 -226
5611 ZT Eindhoven
Netherlands
Email: privacy@here.com