Your privacy in Navigation enabled by HERE

HERE’s privacy policy explains how we process your personal data when you use our products and services. In addition, the following information applies to your use of your Navigation system enabled by HERE and its features (the “Service”). The Service is a connected always-on navigation experience and includes features designed for use by a driver as well as passengers in the vehicle.

The purpose of this document is to give background information on data processing for different features available in 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. The Service may also enable your vehicle manufacturer to request data from the Service e.g. to synchronise information related to your drives to access from other screens and devices. Please note that the Service is defaulting to a connected, online, experience.

Your agreement with these terms implies your responsibility for ensuring that this information is passed on to other users of the vehicle, such as co-drivers or passengers, and ensure that these users also accept these terms.

What information do we collect?

We collect the following categories of information:

Registration and contact details

Some features may require the creation of an in-vehicle profile with your vehicle manufacturer, for example when you want to share your location with other users or sync your favourites with your account you may have with your vehicle manufacturer. You may continue to use other available features of the Service without creating such a profile and signing in.

Please note that the in-vehicle profile may be controlled by the vehicle manufacturer.

Location data and place information

Our Service makes use of information about your actual location (“Location Data”) and expressed interests in points of interest (“Places Data”). Location Data reveals where you currently are or where you have been. Location Data is based on available positioning methods, such as GPS. Places Data is general information pertaining to particular geographical locations (e.g. a city or a location of a restaurant) that you may have provided to us, for example your favourite places.

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 application acquires your current location using underlying positioning technologies in the vehicle.

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 content, services or offerings or share your location. As further defined below, Location Data may be collected when you use the navigation feature for service improvement purposes without identifying you personally. Places Data may be sent to HERE for example when you synchronise your favourites.

Navigation functionality

The navigation features of the Service enable you to see the current position of your vehicle on the map, search for addresses and places and request for traffic-aware routing options. It also allows to store and provide access to the last destination searches and favourites.

The connected navigation experience includes both offline cache and online update options for the map content. During your drive, if your vehicle doesn’t already have the map content for the region of your drive available in the local memory, the map content will be dynamically requested and downloaded alongside your drive from HERE servers, for the upcoming route ahead.

During your drive, you may also benefit from turn-by-turn, manoeuvre-based visual and voice guidance instructions, enabling you to follow the planned route. This guidance can be combined with notifications for low fuel or low charging level situations and with automatic retrieval of nearby fuel or charging stations around your then-current position and along your planned route.

If you also enable dynamic route guidance feature, your vehicle will request for alternative routes on regular intervals from the HERE servers. Alternative routes are calculated considering the current traffic situation on these routes.

Synchronisation functionality

With the synchronization experience, you may be able to synchronise your current vehicle position, stored favourites, planned destinations and routes as well as current ETA to your mobile device or other screens or devices.

Depending on your version, the synchronization feature may be either provided by your vehicle manufacturer or HERE.

Traffic improvement

Whenever you use the Service while having traffic features enabled, the Service sends, on 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 analysed 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 and it may be sent to us on your next connection.

My Commute

You may activate My Commute feature in the Service to let the Service learn your daily commutes and help you optimise 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 is automatically synchronised to our servers. This information can be further assigned to an online account or profile.  

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

Technical information and your transactions

During each initialization of the Service, the Service connects to the online configuration database to retrieve current updates available to your software and check for available updates. New available configurations are automatically downloaded. If the configuration includes a new feature which significantly impacts on the processing of your personal data, you will be notified of such functionality separately.

During each online connection, either for software update purposes or during normal use, 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 connection as well as your transactions with HERE may be automatically collected by HERE.

Functionalities provided by other parties

The Service provides a mechanism to extend the features and functionalities of your experience with functionalities provided by parties other than HERE, such as your vehicle manufacturer or other parties who may offer services to you. Such additional functionalities may require further action and a separate consent from you to benefit from. You will be informed of such functionalities which require specific attention from you upon introduction of such new features and functionalities. Also the provider of the functionality will be informed to you during introduction of such feature offered by other parties.

Please refer to the separately provided privacy related information in context of such functionality provided by other parties during the introduction of such feature and also recognise and familiarise yourself with the party offering such functionality to you. We are not responsible on the behaviour and conduct of such third parties offering services directly to you.

How do we use that information?

Non-personal use of Location Data and Places Data

We do not associate your Location Data or Places Data with your other personally identifiable information, such as your profile, unless you have asked us to do so or unless you use such features mentioned above which require association to your profile. For example, if you point to a position in a map to favourite it we do not combine this information with your Location Data unless you have asked us to do so. We implement appropriate technical and organisational measures to prevent associating your Location Data with other personally identifiable information without your permission.

Provision of the Services

As explained in more detail in the privacy policy, the information collected by the Service is utilised to provide you with the Service, to develop our products and services as well as to communicate with you.

We may also use the information to provide you with more improved search and recommendations to better assist you to find a place you may like.

What is our legal basis for processing your Personal Data?

We process your personal data in context of the Service for the following legal bases:

Performance of a contract with you

We process your personal data to perform our obligations under the Service Terms.

Your consent

This Service enables you to activate additional optional features, with great additional functionalities and help us improve the Service.

Once you activate an optional feature or functionality, we process your personal data based on your consent. You may revoke your consent by changing your settings at any time in Settings or About. 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. Some of the features in the Service might be only available based on consent.

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. 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 anonymised. You may contact the HERE Privacy Office at privacy@HERE.com to obtain additional information about retention of your personal data.

Your choices

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

The Service works best in online mode. You may be able to download a portion of the map content to your vehicle to minimise map download activity. Note, that your vehicle may additionally 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 locally in the vehicle and associate that with an online account with features which help you store and synchronise 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.

You may delete a local profile, which will delete all locally stored information associated to your profile, such as recent destinations. Deleting a local profile from the vehicle will not delete any online accounts you may have created.

You may also delete any personal data associated to your local profile.

Do we share your information?

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

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. As noted above, the Service allows to extend the features and functionalities include other services provided by parties other than HERE. Such third party offering such functionality acts as the controller of your personal data, unless otherwise informed.

As explained in more detail in our privacy policy, we may share your personal data:

• with your consent;
• with HERE companies and authorised third parties, who process personal data on our behalf;
• where there is a legal requirement to do so. 

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.

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.

The Service may also include content from and links to third party sites and services. As noted above, the Service allows to extend the features and functionalities include other services provided by parties other than HERE. Such third party offering such functionality acts as the controller of your personal data, unless otherwise informed.

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.

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

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

5611 ZT Eindhoven
Netherlands

Email: privacy@here.com