Mobility Products Privacy Policy
This Mobility Products Privacy Policy (“Privacy Policy”) describes our practices with respect to your information when you use the HERE Mobility websites (“Websites”), software, products, features and other services which this Privacy Policy is part of or refers to (“Services”). The Services are owned, directly or indirectly, by HERE Global B.V., or one or more of its direct or indirect affiliates (collectively, “HERE”, “Company”, “our”, “we”, or “us”). Capitalized terms which are not defined herein, shall have the meaning ascribed to them in the Mobility Products Terms of Use (“Terms”), to which this Privacy Policy is incorporated by reference.
We respect your privacy and take it seriously. This Privacy Policy describes the types of information about you that we collect about you in connection with your use of the Services. This information includes information you may provide to us when you use, register for, interact with or transact via the Services and information we collect from other sources. The Privacy Policy also describes our practices for collecting, storing, using, maintaining, protecting, disclosing, and disposing of such information. This Privacy Policy is also aimed to assure you of our firm commitment to safeguarding the privacy and security of your information.
If you are accepting this Privacy Policy on behalf of a company or other legal entity, you represent that you have the authority to bind such entity to the terms and conditions of this Privacy Policy. If you do not have such authority, or if you do not agree to all the terms and conditions in this Privacy Policy, you may not use the Services.
The term “personal information” as used in this Privacy Policy, shall have the definition ascribed to it in applicable law.
For California Residents: information regarding our privacy practices related to the California Consumer Privacy Act (“CCPA”) is available at the end of this Privacy Policy.
WE URGE YOU TO READ THIS PRIVACY POLICY AND MAKE SURE THAT YOU FULLY UNDERSTAND AND AGREE WITH IT. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DISCONTINUE AND AVOID USING OUR SERVICES.
Table of Contents:
1. General Background
2. Information We Collect
3. How We Use the Information?
4. How Your Personal Information is Shared or Disclosed?
5. Data Transfer
6. How Do We Protect Your Information?
7. Your Choices
8. Modifications to this Privacy Policy and to the Services
9. Contacting Us
Additional information for California Residents
1. General Background
What this Means. This Privacy Policy applies to all users of the Services with specific terms as applicable to each Service they use. As such our role with respect to your personal information is derived from the way you access and use the Services.
This Privacy Policy applies to all users of the Services, as follows (each of which shall be referred to as “user” or “you”):
· Passengers: individuals who seek and book transportation services via the Services, directly or by using a third-party to do;
· Drivers: individuals who: (i) provide transportation services as members of fleets of independent third-party providers of transportation services (“Transport Providers”), and (ii) do not use a driver mobile app provided by us in connection with the Services. The privacy policy that applies to drivers that use the driver mobile app is available here and in the driver app;
· Users of our business partners: individuals who access and use the Services on behalf of our business partners which are Transport Providers, third-parties that manage their transportation services via a specific Service (“Transport Partners”) and third-parties that enable passengers to have access to transportation services (“Demand Partners”, and all collectively “Business Partners”); and
· Websites visitors: individuals who access and use our Websites.
2. Information We Collect
What This Means. We collect information about your use of the Services and your mobile device (if applicable), as well as information you voluntarily provide while using and registering for the Services. In addition, we collect information about you from other sources as described below. The types of information we collect are detailed below.
2.1 Information You Provide.
(a) Registration/Account Information
When you register and create your account to enable your use of the Services, we collect certain personal information including your name, phone number and if relevant your email address. We may also collect additional information you provide to us, such as financial information (for example; payment method and credit card number), and additional authentication information, to provide you with the Services you need (such as payment), or to ensure the integrity of the Services (for example, prevention of fraud). The personal information regarding your account as a Passenger comes directly from you, and if you use the Services as User of a Business Partner it may be provided to us from the relevant Business Partner to enable you to use the Services.
You may edit certain of your personal information at any time by using the features of your account or by sending us an email to: mobility.support@here.com.
(b) Support Information
When you interact with us via support or feedback, we will collect certain personal information generated by your use of the Services or personal information that you choose to share with us to better respond to your inquiries. We may, in accordance with applicable law, document your communication with our support team or with other similar contact channels.
(c) Location Data and Travel Routes
When you grant the Demand Partner permission to access your Location Data to enable the Services, we collect and use information about your actual geographic location (“Location Data”). Location Data reveals where you currently are and/or where you have been. Location Data is based on available positioning methods, such as Assisted GPS.
When you enabled your Location Data, we will use it for purposes of providing you with relevant offers from Transport Providers and public transportation (if applicable). You have the ability to disable the location feature of any mobile app you use via your mobile device’s settings at all times. However, should you do so, the Services will not function or operate as intended.
Your actual geographic location (“Location Data”) reveals where you currently are and/or where you have been. Location Data is based on available positioning methods, such as Assisted GPS. In many mobile device models, the user interface of the mobile device identifies the use of positioning with an arrow icon.
· When you grant the Demand Partner permission to access your Location Data to enable the Services (whether via its mobile app or otherwise), we collect and use information about your Location Data for purposes of providing you with relevant offers from Transport Providers and public transportation (if applicable).
· When you book transportation services via the Services we may provide you with the ability to access and use a web-based ride tracker via text message, that will enable you to track the progress of your driver on a map (if available), to see how far the driver is from your location on a map, and to track the progress of your ride on a map. If you chose to use this feature you will be asked to grant us permission by your web browser. Once you grant us this permission, it will be active each time you chose to access the web-based ride tracker until such time that you disable this permission in your web browser. We do not control your browser location settings and therefore, to learn more about how your browser collects Location Data or to disable it, please refer to the following: for Chrome, at: https://support.google.com/chrome/answer/142065?co=GENIE.Platform%3DDesktop&hl=en, for Safari, at: https://support.apple.com/en-us/HT204690, and for Firefox, at: https://support.mozilla.org/en-US/kb/does-firefox-share-my-location-websites.
You have the ability to disable the location feature of any mobile app you use via your mobile device’s settings at all times, and of any webpage/website you use via your browser settings at all times. However, should you do so, the Services may not function or operate as intended.
2.2. Information We Collect Automatically
Device and Technical Information.
When you use the Services, we will also collect the following data, each to the extent applicable to the Services that you use: device information that includes device ID or any other unique device/user identifier, advertiser ID, publisher ID, device type and model, device manufacturer, the applicable Services version, our Business Partner relevant user ID (if relevant), operating system and version, browser type and version, city, language, time stamp, IP address, screen resolution.
2.3 Information Collected from Other Sources
(a) Information Provided to Us When You Book and Complete A Ride
When you request transportation services as a Passenger through the Services, the following information will be collected by us either from you or from our relevant Business Partner requesting the ride on your behalf:
· Ride request details: pick-up and/or drop-off location, and any additional requirements you may have such as number of passengers, suitcases, etc.
· User details: your name and phone number.
· Additional details: any special requirements you have for the ride that you may choose to share with us during the booking process and add for your ride when you book it.
(b) Information Provided to Us on Drivers from Transport Providers
When you provide your transportation services as a Driver in connection with the Services, the following information will be collected by us from the relevant Transport Provider:
· Driver details: your name, phone number and optionally your photo.
· Location details: your location and distance from the pickup location.
· Vehicle details: the license plate number, make and model of the vehicle you use.
Please refer to the privacy policy of the Business Partners to understand more about how they will treat the personal information you provide to them. We are not responsible for the privacy practices of others and we recommend you read their privacy notices.
(c) Direct Marketing Communication
When you sign up to receive marketing communication from us including news regarding the Services or request certain marketing information from us, we will collect and process your name and email address and optionally your business phone number, in order to comply with your request. We may also collect additional information such as your role or job title at the company you work for and details about the company you work for. You may withdraw your consent by sending us written notice by email to the following address: mobility.support@here.com or by pressing the “Unsubscribe” button in the email.
(d) Usage Analytics
When you use the Services, we may collect information related to your usage patterns and interaction with the Services, including the duration of your use of the Services, information regarding your clicks and error diagnostics, including start and stop events, menu items accessed, and features selected or default values changed. We may also collect error diagnostics information including for example which actions led to the error. We collect this information with your consent, to provide you with a better experience while using the Services and to provide you with technical support.
(e) Information We Collect from Third Parties
We may collect information about you from other sources that may include your personal information. These sources may include the following: (i) consumers or other third parties, providing feedback such as ratings or compliments; (ii) third parties providing your information in connection with any referral program; (iii) third parties requesting services for or on your behalf; (iv) third parties providing information in connection with any claims or disputes; (v) our authorized third-party service providers, such as payment providers and social media services; (vi) financial services providers (if you are a Partner); (vii) publicly available sources; and (viii) marketing service providers. Please note that we may combine the information collected from such sources with other information which is in our possession.
2.4 Text Message/Email Communication
We may contact you, via text message to facilitate the Services to you. You may opt out of receiving text messages from us by clicking on the unsubscribe link which is part of the text messages you receive, or by sending us an email to: mobility.support@here.com.
Please note that we may also contact you, via text messages or email, with important information regarding the Services, your account and verification purposes. For example, we may notify you (through any of the means available to us) of changes or updates to the Services, payment issues, service maintenance, etc. You will not be able to opt-out of receive such service messages.
3. How We Use Your Information
What This Means. We use the information we collect as described in this section.
3.1 General
We use the information that we collect to conduct our business and to provide you with the best possible products and services. Examples of how we use your information include:
· To provide you with the Services, including and if relevant, to provide you with relevant taxi and public transportation offers;
· To create, process, maintain and service your account (if relevant) and send you technical notices, updates, security alerts and support and administrative messages;
· To enable communications between passengers and drivers. For example, a driver may call or text message a passenger to confirm a pickup location;
· To communicate with you, such as when you call us, make a request or inquiry, or share a comment or concern;
· To send you marketing and advertising communications relating to our products or services. (for information about how to manage these communications, please see Section 7 below);
· To improve and optimize the Services (for example, by generating analytics about how our customers use the Services and to assess the success of our marketing and advertising campaigns);
· To detect, investigate and prevent fraud, security risks, misuse of the Services, violations of this Privacy Policy or the Terms, and other illegal activities, and protect our and others’ rights and properties;
· To respond to court orders, lawsuits, subpoenas, and government requests; and
· To carry out any other purpose readily apparent to you or described to you at the time the information is collected.
3.2 Cookies and related Technologies
We may use cookies, web beacons and other similar technologies including such technologies provided by third parties to: (i) operate and improve the Services (including the Websites) and related services, (ii) serve and measure the effectiveness of advertising campaigns, (iii) and analyze the Services traffic and trends, and (iv) the online behaviors and interests of users who interact with the Services. Please review our Cookie Policy to find out more about how we use cookies and how you can disable cookies by browser settings or otherwise.
In addition, we may use elements provided by third-parties such as cookies, web beacons, SDKs, and other similar technologies that are placed by these third parties on our behalf to identify your device when you visit the Websites and use the Services, as well as when you visit other online sites and services. We use the services of certain third parties to provide us with audience measurement and analytics services, to serve advertisements on our behalf across the Internet, and to track and report on the performance of such advertisements. Third parties’ use of cookies, web beacons, SDKs, and other similar technologies is governed by the privacy notices of those third parties, and this Privacy Policy does not apply to the data processing activities of those third parties. Please consult our Cookie Policy to find out more about the third-party services we use. We do not control how third-party partners process your data, and we encourage you to visit their websites to learn more about their privacy practices.
We use Amplitude for analytics and to determine which areas of these Services users like and don’t like, based on traffic to those areas, and which allows us to collect metrics on how users interact with the Services. You can learn more about how Amplitude protects your personal information by clicking here:https://amplitude.com/privacy.
We also collect social media handles, content, and other data posted on our official social media pages and information (such as email address and other information) you allow to be shared through our social media apps, tools, widgets and plug-ins.
Learn more about your choices and how to opt-out of tracking technologies:
In order to delete or block any tracking technologies, please refer to the “Help” area on your internet browser for further instructions, or you may also opt out of third party tracking technologies by following the instructions provided by each third party service provider in its privacy policy listed above or visiting www.youronlinechoices.eu. Please note however that deleting any of our tracking technologies or disabling future tracking technologies may prevent you from accessing certain areas or features of the Services that operate on the web or may otherwise adversely affect your user experience.
3.3 How Your Non-Personal Information is Otherwise Processed
Please note that we may use and/or share information that does not specifically identify you, including in aggregated or statistical form, without restriction, to develop and enhance our products and services, and with third-party business partners, and other third parties.
4. How Your Personal information is Shared or Disclosed
What This Means. Sharing information with certain third parties is integral to the Services. As a Passenger, some of your personal information will be shared with Business Partners and their Users for the purpose of facilitating the Services to you, and as a Driver your personal information will be shared with Passengers and if applicable with Demand Partners. In addition, some of your personal information will be shared with other third parties, such as our affiliated companies, business partners and service providers.
4.1 With Business Partners
· When you use the Services as a Passenger, and in order to provide the Services to you, Business Partners and their Users can see and access information about you in circumstances such as when you are using the Services to book and/or take a ride via Demand Partners’ products or services, your personal information, such as your name, phone number, desired pick-up and drop off locations, and any other information you choose to share during the booking stage, will be shared with: (i) the relevant Demand Partner (and its representatives); (ii) the relevant Transport Provider whose transportation services you booked; and (iii) the relevant driver providing you with the transportation services.
Please refer to the privacy policy of the relevant Business Partners you choose to understand how they will use your data.
· When you provide your transportation services to Passengers as a Driver, Passengers and if relevant, Demand Partners and their Users can see and access information about you in circumstances such as when your transportation services are booked on behalf of a Passenger and not by the Passenger directly.
4.2 With Affiliated Companies
We will share information with our affiliated companies, to the extent they are providing us with services, as may be required for the purposes of processing as described above or otherwise as specifically described in this Privacy Policy.
4.3 With Our Authorized Third-Party Service Providers
We share personal information with authorized third-party service providers we use in order to facilitate, provide and enhance the Services, operate the Websites, fulfil obligations imposed on us by applicable laws and regulations, and prevent fraud and illegal activities. We take commercially reasonable steps to require third-party service providers to adequately safeguard your personal information and only process it in accordance with our instructions.
The following are the categories of third-party service providers that we use: (i) analytics and product optimization tools, (ii) community management services, (iii) user communication services, (iv) hosting services; (v) technical support services and forum hosting; (vi) user acquisition tracking services; (vii) viral campaign tracking services; (viii) targeting and retargeting services; (ix) third party payment vendors; (x) customer relationship management and mailing vendors, (xi) marketing partners and marketing platform providers, and (xii) professional service providers.
4.4 Mergers and Acquisitions
If we decide to sell, buy, merge or otherwise reorganize our business in certain countries, this may involve disclosure of personal information to other HERE affiliates, prospective or actual purchasers and their advisers, or receiving personal information from sellers and their advisers.
4.5 As Required by Law or in Relation to Legal Proceedings
We may be obligated by mandatory law to disclose your personal information 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 information in accordance with applicable law to defend our legitimate interests, for example, in civil or criminal legal proceedings.
4.6 Aggregate Data
We may use and/or share your information in anonymous form, meaning it cannot identify you as an individual, including aggregated data, without restriction, including with existing and prospective third-party business partners, researchers and advertisers. We do not sell, rent, or otherwise share your information with third parties, except as described in this Privacy Policy.
5. Data Transfer
What This Means. Your information, including personal information might be transferred outside the country where you use the Services.
The Services may be provided using resources and servers located in various countries around the world. Therefore, your personal information may be transferred across international borders outside the country where you use the Services or access our Websites. If you have any questions about the transfer of your information to other countries, please email us at: mobility.support@here.com.
6. How We Protect Your Information?
What This Means. We use standard industry protocols and technology to protect your personal information.
The Services incorporate safeguards designed to protect the security, integrity, and privacy of the personal information we have collected. We have put in place reasonable precautions to protect information from loss, misuse, and alteration, including Secure Socket Layer (SSL) technology on the Services. When we collect personal information from you when using the Services, such information is encrypted and transmitted in a secure way. Please note that while we take steps to safeguard your personal information, we have no control over how other users of the Services and the public at large may use the information you choose to share while using the Services.
7. Your Choices
What This Means. You may update, correct or delete your account by contacting us and may also unsubscribe from receiving certain communications from us.
You may update, correct or delete your account information (if relevant) at any time by contacting us as indicated in the Contacting Us section below.
If, at any time, you prefer not to receive further communications from us (except in connection with information, products or services that you specifically request), you will have the ability to unsubscribe from such communications by means of a link provided in every email or text message that is sent to you by us. If, at any time, you prefer not to receive any other form of communication from us, you will have the ability to unsubscribe from such communications by contacting us as indicated in the Contacting Us section below.
8. Modifications to this Privacy Policy and to the Services
What this Means. We reserve the right to modify this Privacy Policy, and we will notify you and ask for your consent through the Services in case of modifications that materially change the treatment of personal information.
We may modify this Privacy Policy at any time, at our discretion, and modifications are effective upon being posted on any part of the Services, the next time you use the Services whether by pop-up notification or otherwise. Such modifications will not change the scope of our collection or use of your personal information collected before such modifications. The date on which this Privacy Policy was last revised is identified at the top of the page. If we make material changes to how we treat your personal information, we will also ask for your consent to such changes through the Services. In case you choose not to provide your consent upon a material change, we may need to close your account.
The features of the Services, including features that involve data collection, use, and disclosure, will evolve over time as we develop new, or discontinue existing, functionalities for the Services. We may require registration or consent for additional features that may be developed or added to the Services from time to time. When we add new features to the Services that involve processing personal information, we will update this Privacy Policy and notify you of the changes. When we discontinue features that involve processing your personal information, we will cease using your personal information for the purposes of providing those features.
9. Contacting Us
What this Means. You may contact us either via email or post mail at these addresses.
Questions or concerns about this Privacy Policy can be directed to us via email at mobility.support@here.com or at:
HERE Global B.V
C/O Privacy
Kennedyplein 222 -226
5611 ZT Eindhoven
The Netherlands
The Company’s Data Protection Officer can be contacted at:
Emmanuel Salami
HERE Deutschland GmbH
Invalidenstrasse 116
10115 Berlin
Germany
Email: mobility.privacy@here.com
If you are not satisfied with the Company’s response or believe we are processing your personal information not in accordance with the law, you have the right to lodge a complaint with your local Data Protection Authority. Contact information for your local Data Protection Authority can be found here: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
Additional Privacy Information for California Residents
The California Consumer Privacy Act (CCPA) provides California residents with additional rights with respect to their personal information. The law is in effect as of January 1, 2020.
The term “personal information” under the CCPA means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or household.
Please note that for purposes of addressing the rights of California residents the term personal information as used in this Privacy Policy shall mean personal information for the purpose of this Additional Information for California Residents.
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 not to be discriminated against, this Section also does not apply to our handling of personal information of 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.
Categories of Personal Information we Collect, Use and Disclose
The table below generally sets out the categories of personal information that we collect use and disclose to others for a business purpose. We collect these categories of personal information from the sources described in the Section above titled “Information We Collect”, and for the purposes described in the Section above titled “How We Use Your Information”. Our collection, use and disclosure of personal information about a California resident will vary depending on the circumstances and nature of our interactions or relationship with such resident.
Categories of personal information |
Do we collect? |
Do we disclose for a business purpose(s)? |
Categories of third parties to whom information is disclosed |
Name, Contact Information and other Identifiers: Identifiers such as a real name, alias, address, Internet Protocol (IP) address, email address, account name, or other similar identifiers. |
YES |
YES |
See Sections 3.2 and 4 above. |
Customer Records: Paper and electronic customer records containing personal information, such as name, address, telephone number, current employment, driver’s license, credit card number, debit card number, or any other financial or payment information. |
YES |
YES |
See Sections 3.2 and 4 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 |
See Sections 3.2 and 4 above. |
Usage Data: Internet or other electronic network activity information, including, but not limited to, search history, usage history and information regarding a resident’s interaction with an internet website, or application, including access logs and other activity information related to a resident’s use of any Websites, applications or other online services. |
YES |
YES |
See Sections 3.2 and 4 above. |
Geolocation Data: Precise geographic location information about a particular individual or device. |
YES |
YES |
See Sections 3.2 and 4 above. |
Audio, Video and other Electronic Data: Audio, electronic, visual, thermal, olfactory, or similar information such as, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars). |
YES |
YES |
See Sections 3.2 and 4 above. |
California Consumer Rights
The following are the additional rights that you have as California resident:
(a) Right to Know. You have the right to know and receive a copy of the data we have collected about you over the prior 12 months period, free of charge, including:
· The categories of personal information we have collected about you;
· The categories of sources from which your personal information is collected;
· The business or commercial purpose for collecting and selling your personal information;
· The categories of third parties with whom we have shared your personal information and the categories of personal information we have shared; and
· The specific pieces of personal information we have collected about you.
Please note that we share your personal information with service providers only as set forth in this Privacy Policy. At present, we do not sell any personal information that is accessed or collected by us in connection with the Services. To our knowledge, we do not sell information of individuals who are under the age of 16.
(b) Right to Delete. You have the right to request that we delete the personal information we have collected from you (and direct our service providers to do the same). However, this right is subject to certain exceptions, as set forth under the CCPA.
(c) Right to not be Discriminated Against. You have the right not to be discriminated against for exercising any of your rights under the CCPA.
(d) Right under California’s Shine-the-Light Law. You have the right to request, free of charge, certain information about your personal information (if any) that we have shared with third parties for their own direct marketing purposes. This request may be made once per a calendar year.
Exercising Your California Privacy Rights.
To exercise your rights under the CCPA, you or or your authorized agent may contact us as follows:
Website: You may contact us by filling out the webform available here.
Email: You may email us to exercise rights at mobility.support@here.com. Please include your full name, phone number or email address associated with your use of Services, (as applicable) together with the reason you are contacting us so that we can process your request in an efficient manner.
Phone: you may contact us by phone at +1 (844) 311-6667 (toll free).
When you submit your request, we will need to verify your identity. For example, we may ask you to submit additional information (such as the email address or phone number you have used in connection with the Services) or use identity verification services. 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 note that to protect the privacy and security of your personal information, we will only complete your request if we have succeeded in verifying your identity.
Response Time and Format.
We aim to respond to a request for access or deletion within 45 days of receipt of the request. If we will require more time, we will notify you, in writing, of the reason and the extended period.
Your Privacy Rights Under California’s Shine-the-Light Law
If you are a resident of the State of California and you have provided your information to us, you also have the right to request a list of all third parties (if any) to which we have disclosed your personal information for their own direct marketing purposes. Under California law, you have the right to submit such a request to us and receive the following information:
· The categories of personal information we have disclosed to third parties for third parties’ direct marketing purposes during the preceding year (if any); and
· The names and addresses of third parties that received such personal information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.
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 mobility.support@here.com. In your request, please attest to the fact that you are a California resident and provide a current California address.