HERE WeGo, HERE application or HERE Maps Privacy Supplement (updated) Effective date: Tuesday, 12 February, 2019 <p>We respect and take your privacy seriously.
In addition, this HERE WeGo, HERE application or HERE Maps Privacy Supplement (updated) (“Privacy Supplement”) describes our practices with respect to your information when you use the HERE WeGo, HERE application and HERE Maps (collectively, the “Service”).
The purpose of this Privacy Supplement is to give you background information on data processing for different features available in the Service.
The features of the Service enable you to find places and addresses on a map, interact with them and access relevant content, locate yourself on a map, as well as to enable you to use transportation provided by third parties and facilitated by us.
With navigation you are able to find the optimal route to your destination, even inside buildings.
You can relive and share your location experiences with your friends on different Social Networking Services (“SNS”).</p>
<p>We encourage you to familiarise yourself with the privacy policies of third party services, when you interact with them.
HERE is not in control or responsible for the contents and features of third party services.</p>
<p>Your use of the Service is subject to the HERE WeGo, HERE application and HERE Maps Service Terms (“Terms”) and indicates your agreement to them and your acknowledgement of this Privacy Supplement. </p>
<p>Please note that the features of the Service may depend on how you access the Service.
Different device models and software versions of the Service may offer different features.</p>
<strong>What information do we collect?</strong>
<p>We collect the following categories of information and use it as described in this Privacy Supplement:</p>
<strong>Registration Information </strong>
<p>Some features of the Service may require the use of HERE account, for example when you want to synchronise your collections.
You may continue to use the other features of the Service without signing in.
When you sign-up for a HERE account, we collect your name, email address and your date of birth.
When you are logged in with your HERE account, we will try to automatically synchronise your recent searches and your collections in association with your HERE account.</p>
<strong>Contact Information and Additional Information</strong>
<p>When you use the feature of the Service that enables you to book a ride with any third-party transportation services provider (i.e., a taxi company) (“Transport Provider”), who provides its transportation services to you through such feature, we collect your name and phone number.
In addition, each time you use this feature of the Service to book rides, we collect your relevant pick-up and drop-off locations, pick up time, and any additional information that you chose to provide us with.
For example, when you add notes to your booking.</p>
<strong>Information Provided to Transport Providers</strong>
<p>When you book a ride with your chosen Transport Provider, we provide the relevant Transport Provider with the following information: your name, phone number, pick-up and drop-off locations, pick up time, and any additional information that you chose to provide us with.</p>
<strong>Information Provided by Transport Providers</strong>
<p>After you book a ride with your chosen Transport Provider, we will show you the location of the driver that will pick you up, if it is provided to us from the relevant Transport Provider, on a map or by any other relevant means, until your ride ends.
This data is provided to you, so that you may know where your driver is and may track the progress of the ride.</p>
<strong>Location data and place information</strong>
<p>Our Service makes use of information about your actual location (“Location Data”) and information about places (“Place Information”).
Location Data reveals where you currently are or where you have been.
Location Data is based on available positioning methods, such as Assisted GPS.
In many device models the user interface of the Service identifies the use of positioning with an icon.
Place Information is general information pertaining to particular geographical location (e.g.
city or a location of a restaurant) that you may have provided to us, for example your collections.</p>
<p>Unless otherwise stated, we use random identifiers in connection with your Location Data that do not identify you personally.</p>
<p>When you start to use the Service, the applicable feature of the Service activates your selected positioning methods to retrieve your current location.</p>
<p>The Service may send your Location Data to HERE when you use location enabled features of the Service, such as enable navigation, ask information about nearby services or offerings, use search features, provide you with relevant offers from Transport Providers and public transportation vendors, as well as when the Service asks for new maps for new areas you have navigated into.
Location Data may also be collected when you use the traffic feature for service improvement purposes without identifying you personally.
Place Information may be sent to HERE for example when you synchronise your collections.</p>
<p>You will be asked to allow us to send you push notifications via the application.
We ask you to grant us with this permission for the purpose of enabling us to communicate with you about the Service.</p>
<strong>Information about Service usage</strong>
<p>You may participate to improving our services.
See Your privacy in the HERE Improvement Program for more details.</p>
<p>The Service may include HERE-provided positioning services, including Wi-Fi or other network-based positioning methods.
The use of these technologies and positioning services may involve sharing any or all of the following with HERE: Location Data, speed, direction and timestamp.
number of satellites used in positioning.
parameters of nearby mobile network towers.
parameters of nearby Wi-Fi routers and/or Bluetooth® beacons.
Mobile Country Code and Mobile Network Code of your mobile subscription.
This information is sent to us when you use the Service, after which it is deleted from your device.
We do not use this data to identify you personally or combine this information with your HERE account.</p>
<p>When you decide to use the Traffic features of the Service, Location Data, speed, direction and timestamp are sent from your device to HERE to detect traffic jams, traffic patterns, changed road conditions and other such conditions so that we can provide you with better service.
This information is analysed to distinguish independent routes and traffic patterns and contains an identifier, which is persistent for the duration of the route.</p>
<p>You may choose the extent to which you contribute to the improvement of our services.
In the context of Traffic features of the Service, you can provide us with the Location Data, speed, direction and timestamp, along with the changing identifier, either when you use the Service, when the Service is not actively used or even when the applicable Service is closed.</p>
<p>If the application is closed, we’ll attempt to detect when you’re driving to enable the background collection.
We may use methods available from the mobile operating system or other contextual information to detect driving scenarios.
You can always change your Traffic preferences in the application settings either in Settings or About.</p>
<p>This information is sent to us when you use the Service, after which it is deleted from your device.</p>
<strong>Device and Technical information </strong>
<p>In addition to personal data that you actively provide when you create a HERE account and/or book a ride with a Transport Provider, after you download and install the application, or book a ride via HERE WeGo, certain technical details of your client as well as your transactions with HERE may be automatically collected by HERE, including your device ID or any other unique identifier, advertiser ID (if applicable), publisher ID (if applicable), the device on which you installed the application and/or the device via which you use the Service, operator, device type and model, device manufacturer, application version, operating system and version, browser type and version, city, language, referral URL, IP address, local time, push notification settings, screen resolution, memory and if your GPS is enabled/disabled in your application.</p>
<strong>Support Information </strong>
<p>When you interact with us via support or feedback, we will also collect certain personal data generated by your use of the Service or personal data that you choose to share with us to better respond to your inquiries.
We may, in accordance with applicable law, record your communication with our support team or with other similar contact channels.</p>
<strong>Cookies and Related Technologies</strong>
<p>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 our websites and use the Service, as well as when you visit other online sites and services.
We use the services of these 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.
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. </p>
<p>We use Amplitude for Service analytics and to determine which areas of the Service users like and don’t like, based on traffic to those areas, and allows us to collect metrics on how users interact with the Service. .
This helps us continue to build a better service for you. .
You can learn more about how Amplitude protects your personal data by clicking here: https://amplitude.com/privacy.</p>
<p>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.</p>
<p>We will only use the cookies and related technologies described above with your consent. .
If you want to learn more, please email us at email@example.com with the subject heading “Cookies”.</p>
<strong>Our uses of your data</strong>
<strong>Non-personal use of Location Data or Place Information</strong>
<p>We do not associate your Location Data or Place Information with your other personal information, such as HERE account, unless you have asked us to do so.
For example, if you save a place to your collection, we do not combine this information with your Location Data unless you have asked us to do so.</p>
<p>Please note that we may use and/or share your non-personal data, including in aggregated form, without restriction, including with existing and prospective third-party business partners, researchers and advertisers.</p>
<strong>Provision and development of the Service</strong>
<p>We collect and process your information in order to provide you with the Service, to provide you with a better experience while using the Service, to provide you with technical support and to develop our products and services.</p>
<strong>Communicate with you and make recommendations</strong>
<p>We may also use this information to communicate with you and provide you with more improved search and recommendations to better assist you to find a place you may like.</p>
<strong>Location based advertising </strong>
<p>The Service may include provision of location based advertising or other similar content.
For example if you ask for weather information you may be served with advertising content tailored to that location.</p>
<p>The Service may also include behaviorally profiled advertisements.
For the purposes of providing relevant advertisements to you, we may share your device specific advertising ID to advertising networks.</p>
<strong>What is our legal basis for processing your Personal Data?</strong>
<p>We process your personal data in context of the Service for the following legal bases:</p>
<strong>Performance of a contract with you</strong>
<p>We collect and process your personal data to perform our obligations under the Terms.
For example, we collect your Location Data in order to provide you with navigation services and offer you with transportation options and services to your destinations.</p>
<strong>Our legitimate interests</strong>. </p>
<p>In some circumstances, it may be necessary for us to process your personal data for the legitimate interests of our ongoing business operations or the operation of the Service.
Where we rely on a legitimate interest to process your data, we will only do so when our interests are not outweighed by your individual rights and freedoms.
We process the following data on the basis of legitimate interests: Support Information, and Information about Service usage.</p>
<p>Our legitimate interests are: (i) investigating, preventing, and protecting against fraud, security risks, threats to you and others, and violations of this Privacy Supplement or the Terms.
(ii) protecting and defending our rights and properties, including intellectual property.
(iii) complying with laws and regulations that apply to us, as well as responding to requests from law enforcement or government authorities or as otherwise required by law.
(iv) understanding and improving the usage of our services and products, user experience, and customer relationships.
(v) providing an optimized and enhanced user experience.
(vi) maintaining and improving our Service.
(vii) developing new services and features for our users.
and (viii) communicating with you regarding the Service and, as appropriate, promoting and advertising certain functions available within the Service.</p>
<p>There is certain data which we will only use if you choose to share it with us.
For example, location Data and Push Notifications.
You may withdraw your consent, at any time, via your mobile device’s settings.
Doing so will bar us from processing of your personal data based on your consent from that day onward, but will not impact the lawfulness of the processing of your personal data based on your consent before it was withdrawn.
Please note that some of the features of the Service may only be available to you based on consent.</p>
<p>This Service enables you to activate additional optional features and/or functionalities and help us improve the Service, including Traffic and HERE Improvement Program.</p>
<strong>To comply with our Legal Obligations.</strong> </p>
<p>At times we will process your personal data where it is necessary for compliance with our legal obligations.</p>
<strong>How long do we retain Personal Data?</strong>
<p>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, your personal data related to managing your HERE account (such as name, email address, and account content and preferences) are maintained for as long as they are retained by you within your HERE account.
Other data, such as records of your activity within the Service (as applicable), are typically maintained only for a short period before being anonymized.
You may contact the HERE Privacy Office at <u>privacy@HERE.com</u> to obtain additional information about retention of your personal data.</p>
<p>The Service offers a variety of choices to allow you to control how your Location Data and other information are collected.</p>
<p>You may use the Service in offline or online mode.
No Location Data or other information is sent to HERE if you only use the Service in offline mode.
Please note, that your device may nevertheless continue to store and have already stored information which may be sent to HERE as set forth in this Privacy Supplement.</p>
<p>You choose whether to enable the Traffic feature of the Service and if you participate to HERE Improvement Program.
You may withdraw your consent, at any time, via the application Setting.</p>
<p>You can choose the level at which you participate in the development of HERE’s products and services.
You may separately turn the HERE Improvement Program and Traffic on and off.</p>
<p>You can only enable the Traffic features if you also contribute to the improvement of our services.
Once enabled, you can choose the extent to which you contribute to the improvement of our services: only when the application is running or when the application is running or closed.
Please note that you may be able to independently turn the Traffic layer on and off.
This only impacts the visualization of the Traffic content.</p>
<p>You can switch positioning services on and off using your device settings.
Device positioning settings also control HERE positioning services.
If you configure your device such that you are not using any assisted positioning methods, HERE positioning services will also not be used.</p>
<p>You may also clear your recent searches and destinations from the local storage of the Service.
Clearing local storage will also clear already synchronised recent searches in the next synchronization instance.</p>
<strong>How your Information is shared or disclosed?</strong>
<p>Your Location Data will not be shared with other service providers or advertisers without your permission.</p>
<p>The Service may allow you to share your Location Data or Place Information with a social network or directly with your friends.
The Service also includes content from and links to third party sites and services.
When you interact with these sites and services, you may provide your current location to them.
We recommend that you check your settings and the privacy policies of such social networks or other third parties to understand how they process your information.</p>
<p>When you choose to use public transportation services that Transport Providers, or other third parties may provide or offer to you via the Service, such as taxi rides, bus rides or other transportation means, we will share the following information about you with the relevant Transport Providers to facilitate the ride: your name, phone number, pick-up and drop-of locations (subject to applicable law). </p>
<p>We may use third parties to advertise our content or Service on other online or any Service-based social networking platforms.
When you interact with our advertisements on these platforms, such as clicking on the advertisement, the advertiser or social networking platform collects information such as the platform on which the advertisement appeared, the advertiser ID (if applicable), publisher ID (if applicable) and geolocation.
These third-party platforms may use web technologies, such as cookies, to enable us to display promotional materials when you visit other websites, or other targeting and retargeting technologies, to enable us to display promotional materials when you visit other websites, applications or social networking platforms.
This Privacy Supplement does not apply to such third-party platforms processing your data, and we are not responsible for their processing activities.
<p>(1) with your consent;</p>
<p>(2) with HERE companies;</p>
<p>(3) with authorised third parties, who process personal data on our behalf for purposes described in this Privacy Supplement.
The following are the categories of third-party service providers that we use: (i) analytics and product optimization tools, (ii) beta testing platforms, (iii) user communication services, (iv) hosting services, (v) technical support services.
(vi) user acquisition tracking services.
(vii) viral campaign tracking services.
and (viii) targeting and retargeting services;</p>
<p>(4) As required as part of any mergers and acquisitions we undergo.
<p>(5) As required by law or in relation to legal proceedings.</p>
<p>We do not sell, rent, or otherwise share your personal data with third parties, except as described in this Privacy Supplement. </p>
<strong>What are your rights?</strong>
<p>In certain circumstances, you have the following rights in relation to your personal data. .
Please note that in order for us to verify that it is you making the request we may ask for certain verification information:</p>
<strong> - Right of access </strong>to your personal data (commonly known as a "data subject access request").
This enables you to receive a copy of the personal data that we hold about you.</p>
<strong>- Right of correction </strong>of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data that you provide to us.</p>
<strong>- Right to deletion </strong>of your personal data.
This enables you to ask us to delete or remove personal data in certain circumstance Please note, however, that we may retain your data in certain circumstances in accordance with law, which will be notified to you, if applicable, at the time of your request.</p>
<strong>- Right to stop us processing </strong>of your Personal Data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you would like us to establish the accuracy of such data.
(b) where our use of the data is unlawful, but you do not want us to erase it.
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.</p>
<strong>- Right to portability </strong>of your personal data to you or to a third party.
If you so request, we shall provide you, or a third party that you have chosen, with a copy of certain personal data in a structured, commonly used, machine-readable format.
Please note that this right only applies to information that you initially provided consent for us to use or where we used the information to perform our contract with you.</p>
<strong>- Right to object to processing</strong> of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground and we will consider whether we have compelling reasons to continue to process your data.</p>
<strong>- Right to object to direct marketing </strong>You also have the right to object where we are processing your personal data for direct marketing purposes.</p>
<strong>- Right to withdraw consent at any time </strong>where we are relying on consent to process your personal data.
If you withdraw your consent, we may not be able to provide certain products, content or services to you.
You may always be able to opt out of receiving push notifications from your device Setting.</p>
<p>As noted elsewhere in this Privacy Supplement, however, there are certain functionalities of the Service that cannot be modified or disabled, as they are integral to the functioning of the Service.
For example, location services must be enabled in order for the application to function.
If you disable location services through the general settings of your mobile device, the application will not function, and you will be provided with a prompt upon opening the application that location services will need to be re-enabled.</p>
<strong>Who is the controller of your Personal Data?</strong>
<p>HERE Global B.V.
of Kennedyplein 222 -226, 5611 ZT Eindhoven, the Netherlands is the controller of your personal data.</p>
<strong>Modifications to this </strong>
<strong>and to the Services</strong>
<p>We may modify this Privacy Supplement at any time, at our discretion, and modifications are effective upon being posted on any part of the Service, the next time you use the Service whether by pop-up notification or otherwise.
Such modifications will not change the scope of our collection or use of your personal data collected before such modifications.
The date on which this Privacy Supplement was last revised is identified at the top of the page.
If we make material changes to how we treat your personal data, we will also ask for your consent to such changes through the Service.
In case you choose not to provide your consent upon a material change, we may need to close your account.</p>
<p>The features of the Service, including features that involve data collection, use, and disclosure, will evolve over time as we develop new, or discontinue existing, functionalities for the Service.
We may require registration or consent for additional features that may be developed or added to the Service from time to time.
When we add new features to the Service that involve processing personal data, we will update this Privacy Supplement and notify you of the changes.
When we discontinue features that involve processing your personal data, we will cease using your personal data for the purposes of providing those features. </p>
<p>We advise you to use appropriate consideration when you name your collections.
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.</p>
<p>Please let us know if you encounter any content that you find inappropriate in nature either as part of place details or in street level imagery.
For information concerning the Service, check our <u>support pages</u>.</p>
<p>Questions or concerns about this Privacy Supplement can be directed to us via the following contact details, which are the contact information of our Data Protection Officer, Henri Kujala:</p>
<p>HERE Global B.V <br>
<p>5611 ZT Eindhoven</p>
<p>If you are not satisfied with the HERE’s response or believe we are processing your personal data 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.</p>
<strong>Your California Privacy Rights</strong>
<p>If you are a resident of the State of California and you have provided your personal data to us, you have the right to request a list of all third parties to which we have disclosed your personal data for direct marketing purposes. .
Under California law, you have the right to submit such a request to us and receive the following information:</p>
<strong>- </strong>The categories of information we have disclosed to third parties for third parties’ direct marketing purposes during the preceding year (if any).
<strong>- </strong>The names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.</p>