Consumer Privacy and Service Terms FAQ

 

On August 3, 2015, Nokia Corporation announced an agreement to sell its HERE digital mapping and location services business to a consortium comprising of AUDI AG, BMW Group and Daimler AG (the “Consortium”).  After completion of the proposed sale of Nokia’s HERE location-based business to the Consortium, HERE assumes responsibility for the personal data of that business’ customers.  The questions and answers below provide further details about what happens after the proposed transaction.

 

1. Question: After the proposed sale of HERE, what changes about the way my personal data is collected and processed?

Answer:

After the completion of the proposed transaction, personal data that relates to the HERE services will be collected and processed by HERE.

Apart from the change in ownership, your personal data will be used for the same purposes as Nokia.  HERE is maintaining Nokia’s privacy policy with minor changes to reflect the new ownership.  HERE will collect and use the same types of personal data.  The proposed transaction will not change the purposes for which that data is processed without a separate notice to you.

To read the HERE service terms and privacy policy, please visit https://legal.here.com/.

 

2.  Question:  What are the specific differences between HERE’s privacy policy and Nokia’s previous privacy policy?

Answer:

As explained above, after the proposed transaction is completed, the privacy policy for HERE stays the same in substance, with HERE Global B.V. then responsible for all personal data collected under the policy. 

In addition, HERE is publishing some information to help you understand what will happen at https://legal.here.com.

 

3. Question: Will Nokia retain any of my personal data following the proposed transaction?

Answer:

After the proposed transaction, services not related to the HERE services remain with Nokia and Nokia will continue to be responsible for the processing of personal data relating to those services.  Other than that, HERE assumes responsibility for personal data related to the HERE services.

 

4. Question: If I understand correctly, the HERE service terms and privacy policy only apply to certain services.  How do I know which service terms and privacy policy apply to which services after the proposed transaction?

Answer:  

The proposed sale of the HERE business includes all HERE applications, websites and services, including HERE.com, and HERE Maps (for Android, iOS, Windows and Windows Phone).  The applicable service terms are the HERE service terms, and the applicable privacy policy is the HERE privacy policy.  You can view the HERE service terms and privacy policy at https://legal.here.com/.

 

It is important to note that the Consortium is not purchasing all of Nokia’s applications and services.  Nokia continues to be responsible for any personal data collected and used in connection with the Nokia applications and services that continue to be owned by Nokia, such as Z Launcher.

 

5. Question: I understand that HERE will have responsibility for personal data for HERE Account and the Improvement Program after the proposed transaction.  What does this mean in practice?

Answer:

Nokia Corporation’s responsibility for HERE Account and the HERE Improvement Program will shift to HERE.  This means that after the sale HERE is responsible for this data and HERE will be responsive to your privacy needs. 

In practice:

·         You can continue to access HERE services with your HERE Account.

 

·         If you want to update your profile – for example your email address or phone number or to unsubscribe from receiving newsletters and promotions – you can continue to do that through the HERE Account profile management tool (available at https://account.here.com/).

 

·         If you want to exercise your privacy rights related to the HERE Account, you can contact HERE.  Your request will be addressed by HERE.

 

 

6. Question: On my device and/or application user interface and/or sales box, I still see the word “Nokia.”  After the proposed transaction, am I still interacting with Nokia, or am I now interacting with HERE? Who is receiving my data for each given service?

Answer:

The Consortium is acquiring HERE Maps, including all former Nokia applications and services related to HERE (Nokia Maps, Ovi Maps). Once the purchase is complete, updating all of the text in Nokia’s former devices, services, applications, and packaging will take time.  We are actively working on these updates. However, at all times after the purchase is complete, including during this transition, these services and applications are governed by HERE service terms and privacy policy available at https://legal.here.com. 

 

However, other Nokia applications and services (i.e. Z Launcher and other applications and services that the Consortium is not purchasing from Nokia) continue to be provided by Nokia, and are governed by Nokia’s privacy policy at: company.nokia.com/en/privacy.

 

 

7. Question: Does the proposed transaction change the countries where my data will now be transferred?  After the proposed transaction, will HERE transfer my personal data to the United States?

Answer:

There are no changes in where your data may be transferred to.  Nokia’s privacy policy already informed users that Nokia’s products and services might be provided using resources and servers located in various countries around the world, including countries outside the European Economic Area (EEA), such as the United States.  Some data may be stored in or accessed from locations outside of Europe – but this is not new.  As with Nokia, HERE affiliates in United States comply with the HERE privacy policy regarding the collection, use, and retention of data for people living in the EEA as well as other countries.  Your personal data will continue to be protected by robust privacy and security measures, regardless of where it is located.

 

8. Question: If I want to access my personal data, or want it to be corrected or deleted after the proposed transaction, how can I do that?

Answer:

If you want to exercise your privacy rights after the proposed transaction, you can contact HERE at: HERE Global B.V, c/o Privacy, De Run 1115, 5503 LB Veldhoven, Netherlands.   

 

9. Question: I want my HERE Account to be deleted.  How can I do that?

Answer:

You may deactivate or terminate your HERE Account through “deactivate your account” functionality at https://account.here.com/.

 

10.  Question: Do I need to update my applications or other software due to these changes?

Answer:

You should experience no difference in the functionality of the applications or websites as a result of the proposed transaction. We recommend though to always use the most recent version of the applications available. 

 

11.  Question:  Will HERE share my data with law enforcement agencies who wouldn’t have been able to receive my data from Nokia?

Answer:

HERE complies with applicable data protection and other laws, just as Nokia would have to the extent its data processing was covered under any specific jurisdiction’s laws.  Consistent with Nokia’s privacy policy that applied to the devices and service business, after the proposed transaction HERE may be obligated by law to disclose personal data to certain authorities or other third parties, for example, to law enforcement agencies in the countries where we or third parties acting on our behalf operate.

 

12. Question:  Whom do I contact if I have any questions?

Answer:

You can send any further questions you have about the privacy aspects of the proposed sale to HERE, c/o Privacy, De Run 1115, 5503 LB Veldhoven, Netherlands.