WE CARE ABOUT YOUR PRIVACY

This page describes our practices related to collection, use and disclosure of personal data in connection with our services provided within the United States of America.  Disclosures applicable specifically to California residents are available below.

HERE Global B.V., including its affiliates (“HERE”), is a globally integrated provider of geolocation based platform services.  Our services enable users to change the way they do business.  From autonomous driving, to the Internet of Things, we are building the future of location technology through strategic partnerships. To provide services to our customers, we collect and use personal data.  We respect your privacy comply with all applicable data protection and privacy laws. This privacy policy (“Policy”) describes how we collect and use personal data and how this data is shared with our affiliates and business partners to deliver you services where HERE is the data controller or where we refer to the applicability of this Policy. “Personal data” means information relating to you or another identifiable individual.

We will give you additional privacy information that is specific to a product or service in Supplements to this Policy and other notices you may see while using our products or services. If there is a difference between such notices and this Policy, the notices should be considered first.

Our software may access information about your usage of our services and your device. Our products or services may contain links to, or may be embedded within, other companies’ websites and services that have privacy policies of their own. Where our products or services are embedded to products and services of our customers, we require our customers to provide necessary transparency to you. This might include linking to this Policy and the relevant Supplements, or providing the transparency in integrated and embedded notices which identify us as the service provider or controller.

If you do not agree with this Policy, do not use our products and services or provide HERE with your personal data.

1)  What information do we collect?

We collect your personal data and other information when you make a purchase, use or register for our products and services (including navigation.com stores, which are branded by Original Equipment Manufacturers (“OEMs”) and operated by us), take part in campaigns or research or otherwise interact with us. This includes following categories:

a)  Product and service activations

HERE products and services may require electronic activation.  When you register your device and application type, information about your unique device, application, network and subscription identifiers are sent to HERE.

b)  Use of products and services

When you access our services online, our web servers automatically create records of your visit. These records typically include IP-address, access times, the sites linked from, pages visited, the links and features used, the content viewed or requested, browser or application type, language and other such information. See also our Cookie policy.

Our applications may contact our servers periodically, for example to check for updates or to send us information relating to your service usage. Additionally, we may invite you to join voluntary product and service improvement or research programs where detailed information is collected. See Supplements to this Policy for more details.

c)  Information you provide us with

When you create an account, make a purchase, request services, participate in research or campaigns or otherwise interact with us, we may ask for information such as your name, email address, phone number, street address, user names and passwords, feedback, information relating to your devices, age, gender, and language, bank account number, credit card details and other such financial information.
We also maintain records of your consents, preferences and settings relating to, for example, location data, marketing and sharing of personal data.

d)  Your transactions with us

We maintain records of your purchases, downloads, any content you share with us, and the content of your service requests.  We also maintain copies of your agreements with us, the products and services we have provided to you, payment and delivery information, your contacts and communications and other interactions with us. We may, in accordance with applicable law, record your communication with our customer care or with other such contact points.

e)  Positioning and Location data

Location-based services establish location through the use of satellite, mobile, Wi-Fi, Bluetooth Low Energy (“BLE”) or other network based positioning methods. These technologies may involve exchanging your location data and unique device and mobile, Wi-Fi, Bluetooth, or other network related identifiers with HERE. Our products may operate on multiple device platforms, applications and services which may also collect your location data. We do not use this information to identify you personally without your consent.

When you use our location based services and features, for example location based search, navigation and routing, or request for map data, your location data is sent to HERE to serve you with the right content, which may also include location based advertising.

f)  Information provided by partners

We obtain information from industry partners and a variety of other sources, including publicly available sources such as business registries. We require these sources to comply with applicable laws with regard to collecting and transferring this data to us, including ensuring that there is a legal basis for the transfer or anonymizing the data in accordance with applicable laws prior to disclosure of the data to us.

2)  Why do we process Personal Data?

HERE may process your personal data for the following purposes. One or more purposes may apply simultaneously.

a)  Providing products and services

We may use your personal data to provide you with our products and services, to process your requests or as otherwise may be necessary to perform the contract between you and HERE, to ensure the functionality and security of our products and services, to identify you as well as to prevent and investigate fraud and other misuses.

b)  Accounts

Some services may require an account to help you manage your content and preferences. Depending on the service, an account creation may be either required or voluntary. Account creation requires you to provide us with basic contact details about yourself, such as name, email address, country of residence and date of birth. You may also be able to voluntarily provide more information about yourself while creating a profile, such as a photo or avatar of your choice.

c)  Developing and managing products and services

We may use your personal data to develop and manage our products, services, customer care, sales and marketing. We may combine personal data collected in connection with your use of a particular HERE product and/or service with other personal data we may have about you, unless such personal data was collected for a purpose, where the original purpose is incompatible with this purpose.

d)  Communicating with you

We may use your personal data to communicate with you, for example to inform you that our services have changed or to send you critical alerts and other such notices relating to our products and/or services and to contact you for customer care related purposes.

e)  Marketing, advertising and making recommendations

We may contact you to inform you of new products, services or promotions we may offer and to conduct market research when we have your consent or it is otherwise allowed. We may use your personal data to personalize our offering and to provide you with more relevant services, for example, to make recommendations and to display customized content and advertising in our services. This may include displaying HERE and third party content.

3)  What is our legal basis for processing your Personal Data?

Our legal basis for processing your personal data is dependent on the purpose for processing and may vary as described in the Supplement applicable to the product or service you are using. In general, we process your personal data under the following legal bases:

a)  Performance of a contract with you

We process your personal data to perform our obligations under the Service Terms applicable to the product or service you are using, provided by us or our customers. Our Service Terms are available at https://legal.here.com/terms.

b)  Your consent

We process your personal data if you have consented to the processing activity. You may revoke your consent at any time. 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 of our products and services might be only available based on consent.

c)  Legal obligations

We process your personal data as needed to comply with laws and regulations.

d)  Legitimate interests

We process your personal data to further our legitimate interests, such as in connection with managing, developing, testing, securing, and in limited circumstances marketing, advertising, and making recommendations regarding our products and services. Any such processing is conducted subject to appropriate measures to protect your fundamental rights and freedoms related to your personal data, and in any event will be subject to the restrictions provided in this Policy. Further information or specification of our legitimate interests may be provided in relevant Supplements applicable to the product or service.

4)  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 anonymized or pseudonymized. Additional information may be provided in the Supplement applicable to the product or service you are using. You may contact the HERE Privacy Office at privacy@HERE.com to obtain additional information about retention of your personal data.

5)  Do we share Personal Data?

We do not sell, lease, rent your personal data to third parties. We disclose your personal data to third parties only as stated below.

a)  Your consent and social sharing services

We may share your personal data if we have your consent to do so. Some services may allow you to share your personal data with other users of the service or with other services and their users. Please consider carefully before disclosing any personal data or other information that might be accessible to other users.

b)  HERE companies and other authorized parties

We may share your personal data with other HERE companies, authorized service providers who process personal data for HERE for the purposes described in this Policy, and third parties that you direct us to share your personal data with. This may include for example billing through your network service provider or otherwise, delivery of your purchases, providing services including customer service, managing and analyzing consumer data, credit checks, conducting research and managing marketing and other such campaigns.

We may conduct joint marketing and other communications with our partners. To avoid duplicate or unnecessary communications and to tailor the message to you we may need to match information that HERE has collected with information that the partner has collected where this is permitted by law.

HERE service providers are not permitted to use your personal data for any other purposes. We bind them contractually, require them to act consistently with this Policy and to use appropriate security measures to protect your personal data.

c)  Third-Party Links

Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

d)  International transfers of personal data

Our products and services 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 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://eur-lex.europa.eu/eli/dec_impl/2021/914/oj.

e)  Mandatory disclosures

We may be obligated by mandatory law to disclose your 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. We may also disclose and otherwise process your personal data in accordance with applicable law to defend HERE’s legitimate interests, for example, in legal proceedings or in connection with governmental requests and filings.

f)  Mergers and Acquisitions

If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers.

6)  How do we address the privacy of children?

HERE products and services are typically intended for general audiences. HERE does not knowingly collect information of children without the consent of their parents or guardians. HERE publishes safety guidelines for using internet services in our websites.

7)  How do we address Data Quality?

We take reasonable steps to keep the personal data we possess accurate and to delete incorrect or unnecessary personal data.

We encourage you to access your personal data through your account from time to time to ensure that it is up to date.

8)  What steps are taken to safeguard Personal Data?

Privacy and security are key considerations in the creation and delivery of our products and services. We have assigned specific responsibilities to address privacy and security related matters. We enforce our internal policies and guidelines through an appropriate selection of activities, including proactive and reactive risk management, security and privacy engineering, training and assessments. We take appropriate steps to address online security, physical security, risk of data loss and other such risks taking into consideration the risk represented by the processing and the nature of the data being protected. Also, we limit access to our data bases containing personal data to authorized persons having a justified need to access such information.

9)  How do we use Cookies and Web Beacons?

HERE uses cookies, web beacons and other similar technologies to operate and improve our websites and offerings. We also use cookies for personalization and to display ads. Some HERE websites use third party advertising technologies, such as DoubleClick, to serve ads.

Our domains may include third party elements that set cookies on behalf of a third party, for example relating to third party social network. Please visit our Cookie policy to find out more about how HERE uses cookies and how you can disable cookies by browser settings or otherwise.

10)  What are your rights?

You have a 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 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. You have a right to unsubscribe from direct marketing messages and to request that we stop processing your personal data for direct marketing purposes or on other compelling legal grounds. However, if you opt-out from marketing and other communications from HERE, critical alerts may still be sent to you. 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 through our request submission webform at https://legal.here.com/en-gb/here-data-subject-request or by managing your account and choices through available profile management tools on your device and our services. 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.

11)  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.

In addition, the HERE affiliate providing the product or service may be a controller of your personal data. You may find the identity of the controller and its contact details by reviewing the terms and conditions of such a product or service or by using contact information provided in the applicable HERE websites.

In matters pertaining to HERE’s privacy practices you may contact our Data Protection Officer at:

HERE Global B.V
c/o Privacy
Kennedyplein 222 -226
5611 ZT Eindhoven
Netherlands

Email: privacy@here.com

Webform: https://legal.here.com/en-gb/here-data-subject-request

12)  Changes to this Privacy Policy

HERE may from time to time change this Policy or change, modify or withdraw access to this site at any time with or without notice. However, if this Policy is changed in a material, adverse way, HERE will post a notice advising of such change at the beginning of this Policy and on this site's home page for 30 days. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy.

 

IMPORTANT ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS

In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”), which requires that we provide California residents certain specific information about how handle their personal information, whether collected online or offline.  Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments.

Except for the Right to Opt-out and the Right of Non-Discrimination, this section does not apply to California residents with whom we transact or communicate solely in the context of providing or receiving a product or service to or from a company that employs such residents or engages such residents as contractors. This section also does not apply to personal information we collect about job applicants, independent contractors, or current or former full-time, part-time and temporary employees and staff, officers, directors or owners of HERE Global B.V., HERE North America, LLC or any affiliated entities.

Categories of Personal Information that We Collect, Use, Disclose, and Sell

The table below sets out generally the categories of personal information about California residents that we collect, use, disclose, and/or sell. We do not sell your personal information or disclose it to third parties for a business purpose. We may disclose each of these categories of personal information to our service providers, who are not permitted to use your personal information except as necessary for performing services on our behalf. We collect these categories of personal information from the sources described in the What information do we collect section above, and for the purposes described in the Why do we process Personal Data section above.  Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. 

Please note that the CCPA defines the term “sale” very broadly to include any exchange of data for consideration of any kind, not simply selling your data for monetary compensation. Depending upon the circumstances, “sale” could include providing your data to an entity to assist us with targeted advertising purposes. To our knowledge, we do not sell information of minors under 16 years of age.

 

Categories of personal information	Do we collect?	Do we disclose for a business purpose(s)	Do we sell?	Categories of third parties to whom information is disclosed or sold
Name, Contact Information and other Identifiers: Identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	YES	YES	NO	See sections 5(a), (b), (e) and (f), and section 9 above.
Customer Records: Paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information.	YES	YES	NO	See sections 5(a), (b), (e) and (f) above.
Protected Classifications: Characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.	YES (age only)	YES	NO	See sections 5(a), (b), (e) and (f) above.
Purchase History and Tendencies: Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.	YES	YES	NO	See sections 5(a), (b), (e) and (f) above.
Usage Data: Internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, including access logs and other activity information related to your use of any HERE websites, applications or other online services.	YES	YES**	NO	See sections 5(a), (b), (e) and (f), and section 9 above.
Geolocation Data: Precise geographic location information about a particular individual or device.	YES	YES	NO	See sections 5(a), (b), (e) and (f) above.
Audio, Video and other Electronic Data: Audio, electronic, visual, thermal, olfactory, or similar information such as, CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars).	YES	YES	NO	See sections 5(a), (b), (e) and (f) above.
Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.	YES	YES	NO	See sections 5(a), (b), (e) and (f), and section 9 above.

* While HERE takes steps to prevent such occurrences, personal information such as your name or contact information may be sold as part of a point of interest on our maps, particularly where your name is part of a business name. If you believe your information has been included on our map, instructions for opting out are provided on our sale opt out page.

** In some circumstances transfers of Usage Data collected from visitors to our online properties in connection with advertising and tracking technologies may be considered a disclosure for a business purpose or a sale to a third party such as our advertising technology partners. Please see our sale opt out page and Cookie Policy for more details.

California Consumer Rights

California law grants consumers certain rights and imposes restrictions on particular business practices as set forth below. California consumers have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.

Right to Opt-out of Sale of Personal Information.   California residents have the right to opt-out of our sale of their personal information. More details are provided and opt-out rights can be exercised here.

Requests for Copy, Deletion and Right to Know. Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months. Please see Submitting Requests below for instructions about how to exercise your rights:

Deletion: the right to request deletion of personal information that we have collected about you, subject to certain exemptions.

Copy: the right to request a copy of the specific pieces of personal information that we have collected about you in the prior 12 months. 

Right to Know (Collection): Where we have collected personal information about you, the right to request that we disclose certain information about how we have handled your personal information in the prior 12 months, including: the categories of personal information collected; categories of sources of personal information; business and/or commercial purposes for collecting and selling your personal information; and the categories of third parties/with whom we have disclosed or shared your personal information.

Right to Know (Disclosure and Sale): Where we have sold or disclosed for a business purpose your personal information, the right to request that we disclose certain information about how we have handled your personal information in the prior 12 months, including: the categories of personal information collected; categories of third parties to whom your personal information has been sold and the specific categories of personal information sold to each category of third party; categories of third parties to whom personal information has been disclosed; and the categories personal information that we have disclosed or shared with a third party for a business purpose.

Submitting Requests. You (or your authorized agent) can exercise your rights by:

• Clicking here to access our webform
• Contacting us at 1-833-721-0735 (toll free)
• Emailing us at privacy@here.com

When you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the personal information we maintain about you. As part of our verification process, we may ask you to submit additional information (such as the email address you have used in connection with our services), use identity verification services to assist us, or if you have created an account on our website or mobile app, we may ask you to sign in to your account as part of our identity verification process. If your request is submitted via an authorized agent, we will attempt to verify their authority to act on your behalf, which in some contexts (e.g. where we only know you by your email address or similar information) may require contacting you directly. Please understand that, depending on the type of request you submit, to protect the privacy and security of your personal information, we will only complete your request where we are satisfied that we have verified your identity to an appropriate degree of certainty.

Non-Discrimination. The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA. HERE will not discriminate against you, including by denying or providing a different level or quality of goods or services, charging different prices or rates or imposing penalties, unless doing so is reasonably related to the value provided to HERE by your data.

 

Your California Privacy Rights under California’s Shine-the-Light Law

Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use.  Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to privacy@here.com. In your request, please attest to the fact that you are a California resident and provide a current California address.  

California consumers may direct any questions or concerns regarding HERE privacy policies and practices to privacy@here.com.