HERE Global B.V., including its affiliates (“HERE”), is committed to respecting your privacy and complying with applicable data protection and privacy laws and regulations. HERE is the controller of your personal data for the processing described in this Notice. For more information about our privacy approach, please visit our HERE Privacy Policy.  

Introduction of HERE Improvement Program 

By joining the HERE Improvement Program (“Program”), you provide us important information about how you use our products so we can improve them.  

The Program uses software that is integrated into the applications and services on your device to collect and send small data packets (typically only a few kilobytes per instance) to HERE. 

Purpose description 

Certain HERE applications and services use the Program to help us: 

 - focus our improvement efforts on what matters most to the users;  

 - identify and highlight the features and functionalities users find most interesting;  

 - reduce future errors. 

Note: When an application or service includes the Program, it is explicitly referenced in the Privacy Notice specific to that application or service. 

Legal basis 

Participation in the Program is voluntary and based on your consent. You may revoke your consent at any time by changing your settings in “Settings” or “About”. If you do, we will stop processing personal data based on that consent. Withdrawal of consent does not affect the lawfulness of processing carried out before it was revoked.  

Source of information 

We receive the information directly from you through your interaction with the relevant application or service. 

Personal data involved in the processing activity 

The Program collects the following information about your device, and use of the applications and services on the device: 

 - Device and online identifiers. This may include device model, operator, country, city, random but persistent identifiers associated with the particular event. We may also collect information related to your usage patterns (including the session duration, clicks, and error diagnostics). 

 - Search Improvement. If you further participate in Search Improvement, the Program data will be complemented with search keywords in association with exact location information (latitude and longitude) where a search is performed. This is used to improve the Search feature and is not used to identify you personally. Search Improvement may also collect information about searches conducted offline. 

Excluded content: We collect data without direct identifiers and do not re-identify individuals. The Program does not collect:  

​ - Emails, SMS, notes, or documents 

 - Search content or media files 

​ - Exact location data (latitude/longitude) 

 - Metadata which may be considered personal data  

Categories of data recipients to whom we share your personal data 

We do not share the information collected by the Program with independent third parties. However, if a particular third-party feature is involved, we may share aggregated, nonidentifiable information with that provider. 

Retention period of the processing activity 

We aim to collect only the personal data necessary for the stated purposes and retain it no longer than needed for those purposes. 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. 

International transfer 

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) or the United Kingdom 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.  

Automated decision-making based on personal data 

During this personal data processing, automated decision-making based on personal data does not occur. 

Profiling based on personal data 

During this personal data processing, profiling is not occurring based on your personal data. 

Data subject rights 

Your participation in the Program is voluntary. You may choose to turn the Program on and off at any time in the application or device settings (look for “Improvement Program”). HERE does not have a capability to identify you personally based on the provided data set.  

For more information, please check Your Rights section in our Privacy Policy or submit a request via https://legal.here.com/here-data-subject-request.  

Personal data security 

We prioritize privacy and security in our products and services by assigning dedicated responsibilities and enforcing internal policies in the highest possible scope corresponding to the state-of-the-art technical level. Information stored on your device by the Program is protected against unauthorized access and use. Data is transmitted to our servers using secure protocols. For more information, please visit our Privacy Policy. 

Changes of Privacy Notice 

HERE may update this Notice from time to time. 

Material changes will be communicated through a notice posted at the top of this document and on our website for at least 30 days.