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Mobility Products Privacy Policy




Mobility Products Privacy Policy Effective date:&nbsp;Thursday, 21 March, 2019 <p>This Mobility Products Consumer Privacy Privacy (“<strong>Privacy Privacy</strong>”) describes our practices with respect to your information when you use the Services (as defined below). The Services are owned, directly or indirectly, by HERE Global B.V., or one or more of its direct or indirect affiliates (collectively, “<strong>HERE</strong>”, “<strong>Company</strong>,” “<strong>we</strong>,” or “<strong>us</strong>”).&nbsp. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in the Mobility Products Terms of Use (“<strong>Terms</strong>”), to which this Privacy Policy is incorporated by reference.</p> <p>The term “<strong>Services</strong>” as used in this Privacy Policy means any product or service offered and/or made available by HERE to you hereunder, including without limitation, Kiosk, Mobility for Concierge, Web Widget, Mobility Demand API, Mobility SDK, Ride Tracker, Mobility Supply API, Dispatch System, Mobility Portal, any HERE website via which you may access or use the Services (“<strong>Websites</strong>”), and any related services or products which may be offered by HERE to you from time to time.</p> <p>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.&nbsp. 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.&nbsp. 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.</p> <p>This Privacy Policy applies to: any consumer accessing and/or using the Services to explore, request and/or book transportation and any other related services that we may offer to you via the Services (“<strong>Transport Provider Services</strong>”) that may be available to you via the Services (“<strong>Consumer</strong>”). If you are accessing and/or using the Services as a Partner (as defined below), a Partner representative or any visitor of our Websites, please refer to the HERE Mobility Products Supplemental Privacy Notice.</p> <p>The term “<strong>Partner</strong>” means any one of the following entities/individuals: (a) taxi or private hire company, airline, car/bicycle/motorcycle/scooter rental agency or other third parties that provide consumers with Transport Provider Services by using the Mobility Supply API (“<strong>Transport Provider</strong>”). and (b) hotel, airport or other third parties that provide consumers with access to Transport Provider Services, including without limitations, developers of third party applications, by using at least one of the following Services: Kiosk, Mobility for Concierge, Web Widget, Mobility Demand API or Mobility SDK (“<strong>Demand</strong> <strong>Partner</strong>”). The term Partner shall also include Transport Provider using the Marketplace Dispatcher, and any other provider of Transport Provider Services that only uses the Marketplace Dispatcher (“<strong>Dispatch Partner</strong>”).</p> <p>In addition, Demand Partners who are developers using the Mobility SDK as part of their mobile apps may provide us with certain data of their end-users (“<strong>Developer End Users</strong>”) such as name, phone number and location information (“<strong>End User Data</strong>”) when these Developer End Users use the Services via the Mobility SDK.&nbsp. To this end, these Demand Partners authorize us to access and process their End User Data on their behalf, as further described below in this Privacy Policy.</p> <p>If you are entering into 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.</p> <p>The term “<strong>Personal Data</strong>”, as used in this Privacy Policy, means any information relating to you where you are identified or where you could be identified with reasonable efforts or together with additional information, we have access to, or may be of private or sensitive nature relating to an identified or identifiable individual.&nbsp;</p> <p> <strong>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. &nbsp;</strong> </p> <p> <strong> <u>Table of Contents</u> </strong>:</p> <p>1. Information We Collect and How We Use the Information</p> <p>2. How Your Personal Data is Shared or Disclosed</p> <p>3. How Long Do We Store Information?</p> <p>4. Data Transfer</p> <p>5. How We Protect Your Information?</p> <p>6. Your Rights</p> <p>7. Modifications to this Privacy Policy and to the Services</p> <p>8. Contacting Us</p> <p> <strong>1.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp. Information We Collect and How We Use the Information </strong> </p> <p> <strong>What This Means</strong>. <em>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.</em> <em>The types of information we collect are detailed below. We use that information as described in this Privacy Policy.&nbsp. </em> </p> <p> <strong>1.1 Legal Basis for Processing</strong>.</p> <p>1.1.1<u> To provide the Services</u>.&nbsp. We collect and process your Personal Data in order to provide you with the Services in accordance with our contract with you comprised of the Terms. In order for us to provide you with the Services, we have to process the following information:</p> <p> <strong> <em>(a) Registration/Account Information </em> </strong> </p> <p>When you register and create your account to enable your use of the Services, we collect certain Personal Data including your name, and phone number.We may 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).</p> <p>You may edit certain of your Personal Data at any time by using the features of your account or by sending us an email to:&nbsp;mobility_support@here.com.</p> <p> <strong> <em>(b) Device and Technical Information. </em> </strong> </p> <p>When you use the Services, we will also collect the following data, each to the extent applicable to your use-case: 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 Service version, Partner User ID, operating system and version, browser type and version, city, language, time stamp, IP address, screen resolution.</p> <p> <strong> <em>(c) Support Information </em> </strong> </p> <p>When you interact with us via support or feedback, we will collect certain Personal Data generated by your use of the Services or Personal Data 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.</p> <p> <strong> <em>(d) Information Provided to Us When You Book and Complete A Ride</em> </strong> </p> <p>When you request transportation services as a Consumer through the Services, the following information will be collected by us either from you or from our relevant Partner requesting the ride on your behalf:</p> <p> <strong>&nbsp;- Ride Request details</strong>: pick-up and/or drop-off location, and any additional requirements you may have such as number of passengers, suitcases, etc.</p> <p> <strong>&nbsp;-&nbsp. User details</strong>:&nbsp. your name and phone number.&nbsp;</p> <p> <strong>&nbsp;-&nbsp. User verification</strong>: Your identity and access will be verified via the verification code that we send to your mobile device;</p> <p> <strong>-&nbsp. Transportation and location details</strong>: If applicable, you may receive a text message from us to your mobile device with a link to access the Ride Tracker. The information that we collect includes the location of the driver and the progress of the ride on a map.</p> <p> <strong>-&nbsp. Payment details</strong>: the relevant Transport Provider may provide us with information about the payment method which you used when you pay directly to such provider.</p> <p> <strong>- Additional details</strong>: the relevant Transport Provider may provide us any other information you may have provided directly to such provider with respect to your ride/transport preferences.</p> <p> <strong>Kiosk/Web Widget</strong> - when you use these Services, your Personal Data that we and/or the relevant Partner collect in connection with these Services, is directly provided by you, and we act as independent data controller with respect to such data, and the Partner acts as an independent data controller with respect to such data.&nbsp;</p> <p> <strong>Mobility for Concierge. Demand API</strong> - when you use these Services, your Personal Data that we and/or the relevant Partner collect in connection with these Services, is directly provided by you, and we act as data processor with respect to such data, and the Partner acts as a data controller with respect to such data.&nbsp;</p> <p>Please note that once you book a ride and/or any other service with a Transport Provider of your choice, you enter into a contract directly with the relevant Transport Provider who provides the Transport Provider Services to you.</p> <p> <strong> <em>(e)</em> </strong> &nbsp;<strong> <em>Information You Provide When You Use the Mobility SDK via a Developer Mobile App</em> </strong> </p> <p>(1) When you are using a Demand Partner (who is a developer) mobile app (“<strong>Developer App</strong>”) that incorporates the Mobility SDK to request transportation services, the following information will be collected by us from you:</p> <p> <strong>&nbsp;- Ride Request details</strong>: pick-up and/or drop-off location, and any additional requirements you may have such as number of passengers, suitcases, etc.</p> <p> <strong>&nbsp;- User details</strong>:&nbsp. your name and phone number.&nbsp;</p> <p> <strong>&nbsp;- User verification</strong>: Your identity and access will be verified via the verification code that we send to your mobile device;</p> <p> <strong>&nbsp;- Transportation and location details</strong>: If applicable, you may receive a text message from us to your mobile device with a link to access the Ride Tracker. The information that we collect includes the location of the driver and the progress of the ride on a map.</p> <p> <strong>&nbsp;- Payment details</strong>: the relevant Transport Provider may provide us with information about the payment method which you used when you pay directly to such provider.</p> <p> <strong>&nbsp;- Additional details</strong>: the relevant Transport Provider may provide us any other information you may have provided directly to such provider with respect to your ride/transport preferences.</p> <p>(2) When you are using a Developer App to access and use mapping and location services available via the Mobility SDK, then the following information will be collected by us either from you, or from the relevant developer of the Developer App you use:</p> <p> <strong>- Location details</strong>: your current location from your mobile device’s available positioning methods, such as GPS, if you have granted this access to the Developer mobile app. and the locations of places and geographic points of interest (collectively, “<strong>POI</strong>”) if it is provided by the developer mobile app (via the Mobility SDK).</p> <p>Please note that when you are using a Developer App which incorporates the Mobility SDK to access and use the Services, you are doing so based on the contract you entered into directly with the relevant developer of the Developer App you use.</p> <p> <strong>Mobility SDK</strong>: when you use this Service, your Personal Data that we and/or the relevant developer collect in connection with these Services, is directly provided by you, and we act as data processor with respect to such data, and the developer acts as a data controller with respect to such data.&nbsp;</p> <p>Please refer to the privacy policy of the developers whose Developer Apps you use to understand more about how the developers will treat the Personal Data you provide to them. We are not responsible for the privacy practices of others and we recommend you read their privacy notices.</p> <p>1.1.2<u> In Our Legitimate Interests</u>.&nbsp. 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 Services. 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.</p> <p>Our legitimate interests are:</p> <p>- Investigating, preventing, and protecting against fraud, security risks, threats to you and others, and violations of this Privacy Policy or the Terms;</p> <p>- Protecting and defending our rights and properties, including intellectual property;</p> <p>- Understanding, maintaining and improving the Services and their usage, user experience, and customer relationships</p> <p>- Providing an optimized and enhanced user experience;</p> <p>- Developing new services and features for our users. and</p> <p>- Communicating with you regarding the Services.</p> <p>1.1.3<u> With your Consent</u>. There is certain data which we will only use if you choose to share it with us. If you choose to share this data with us, we will use it for the following purposes only. You have the right to withdraw your consent at any time.&nbsp;</p> <p> <strong> <em>(a) Location Data and Travel Routes</em> </strong> </p> <p>When you grant the Demand Partner permission to access your Location Data to enable the Services, we will use it for purposes of: providing you with relevant offers from Transport Providers and public transportation (if applicable), or to enable you to use the Mobility SDK mapping and location services.</p> <p>When you use the Mobility SDK (as available via a Developer App) or the Demand API (via a Demand Partner mobile app), we collect and use information about your actual geographic location (“<strong>Location Data</strong>”). 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.</p> <p>When you enabled your Location Data, we access and collect your Location Data. <strong>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 Mobility SDK/Demand API will not function or operate as intended.</strong> </p> <p> <strong> <em>(b) Cookies and related Technologies</em> </strong> </p> <p>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.</p> <p>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.&nbsp;</p> <p>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 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> <strong>Learn more about your choices and how to opt-out of tracking technologies:</strong> </p> <p>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.</p> <p> <strong> <em>(c) Usage Analytics</em> </strong> </p> <p>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 these information with your consent, to provide you with a better experience while using the Services and to provide you with technical support.</p> <p>1.1.4 <u>To comply with our Legal Obligations</u>. At times we will process your Personal Data where it is necessary for compliance with our legal obligations. responding to requests from law enforcement or government authorities or as otherwise required by applicable laws and regulations.</p> <p>If you want to learn more, please email us at mobility_support@here.com.</p> <p> <strong>1.2 Text Message Communication </strong> </p> <p>We may use your phone number provided during registration or when booking a ride for the purpose of facilitating 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.</p> <p>Please note that we may also contact you, including via text messages, with important information regarding the Services or 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.</p> <p> <strong>1.3 How non-Personal Data is otherwise processed</strong> </p> <p>Please note that we use and/or share non-Personal Data, including in aggregated or statistical form, without any restriction, including with existing and prospective third-party business partners, researchers and advertisers.</p> <p> <strong>2. How Your Personal Data is Shared or Disclosed</strong> </p> <p> <strong>What This Means.</strong> <em>Sharing information with certain third parties is integral to the Services. As a Consumer, some of your Personal Data will be shared with Partners and Partner Users for the purpose of facilitating the Services to you. In addition, some of your Personal Data will be shared with other third parties, such as our affiliated companies and service providers.</em> </p> <p> <strong>2.1 With Partners and Partner Users</strong> </p> <p>When you use the Services, and in order to provide the Services, Partners and representatives of a Partner (as defined above) who access and/or use the Services on such Partner´s behalf (“<strong>Partner User</strong>”) can see and access information about you in circumstances such as:</p> <p>(a) When you are using the Services to book and/or take a ride, your Personal Data, namely your name, phone number, desired pick-up and drop off locations, and any other information you choose to share, will be shared with the relevant Demand Partner (and its Partner Users) through which you access and use the Services.</p> <p>(b) When you are using the Services to book and/or take a ride, your Personal Data, namely your name, phone number, desired pick-up and drop off locations, and any other information you choose to share, will be shared with the relevant Transport Provider/Dispatch Partner (and its Partner Users) whose Transport Provider Services you book.</p> <p>(c) When you are using the Services to book and/or take a ride, your Personal Data, namely your name, phone number, desired pick-up and drop off locations, and any other information you choose to share, will be shared with drivers who will provide you with the Transport Provider Services you book on behalf of the relevant Transport Provider/Dispatch Partner.</p> <p>Please refer to the privacy policy of the relevant Partners you chose to understand how they will use your data.</p> <p> <strong>2.2 With Affiliated Companies</strong> </p> <p>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.</p> <p> <strong>2.3 With Our Authorized Third-Party Service Providers</strong> </p> <p>We share Personal Data 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 Data and only process it in accordance with our instructions.</p> <p>The following are the categories of third-party service providers that we use: (i) analytics and product optimization tools, (ii) beta testing vendors and community management services, (iii) user communication services, (iv)&nbsp;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. and (x) CRM and mailing vendors.</p> <p> <strong>2.4 Mergers and Acquisitions</strong> </p> <p>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.</p> <p> <strong>2.5 As Required by Law or in Relation to Legal Proceedings</strong> </p> <p>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 our legitimate interests, for example, in civil or criminal legal proceedings.</p> <p>&nbsp;</p> <p>We do not sell, rent, or otherwise share your Personal Data with third parties, except as described in this Privacy Policy.&nbsp;</p> <p> <strong>3. How Long Do We Store Information?</strong> </p> <p> <strong>What This Means</strong> <em>. </em> <em>Your Personal Data is retained as long as you keep your account active or as otherwise necessary for protecting our legal rights or complying with our legal obligations. </em>&nbsp;</p> <p>We will retain your Personal Data related to your account for as long as your account is active, and to comply with our legal obligations, resolve disputes, and enforce the Terms. After you close your account, we may retain your data for up to thirty (30) calendar days to allow us a reasonable time to properly close your account (or, if longer retention of certain data is required under law, we will retain such data for such longer period of time). After such period, we will move your data to a ‘Legal Compliance Only’ folder and will retain your data or any part thereof, solely as required or otherwise permitted under applicable law, whichever is shorter. Our longest retention period is seven years for financial information. Once this period has expired, we will delete your data.</p> <p>If your data is being used in aggregated format, for business purpose, this will not be deleted. Such aggregated data includes, for example, historical usage of the Services, and rides booked. You will not be identifiable from this data.</p> <p> <strong>4.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp. Data Transfer</strong> </p> <p> <strong>What This Means</strong> <em>. </em> <em>Your information, including Personal Data might be transferred outside the country where you use the </em> <em>Services</em> <em>. </em>&nbsp;</p> <p>The 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 the Services or access our Website. For European users, this means that data may be transferred to countries outside the European Economic Area (EEA) or Switzerland 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. If you have any questions about the transfer of your data to other countries, please email us at: mobility_support@here.com.</p> <p> <strong>5.&nbsp;</strong> <strong>How We Protect Your Information?</strong> </p> <p> <strong>What This Means</strong>. <em>&nbsp;We use standard industry protocols and technology to protect your Personal Data.</em> </p> <p>The Services incorporate safeguards designed to protect the security, integrity, and privacy of the Personal Data 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 Data from you when using the Services, such information is encrypted and transmitted in a secure way.&nbsp. Please note that while we take steps to safeguard your Personal Data, 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.&nbsp;</p> <p> <strong>6.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp. Your Rights</strong> </p> <p> <strong>What This Means</strong>. <em>You have a right to access, correct, amend, delete, stop us using or object to our use of your Personal Data or request that we transfer certain Personal Data to a third party, or withdraw the consent you have previously given, at any time. </em> </p> <p>If applicable law grants you such rights and subject to the limitations in applicable law, you may have the following rights in relation to your Personal Data:</p> <p> <strong>- Right of access </strong>to your Personal Data. This enables you to receive a copy of the Personal Data that we hold about you.</p> <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&nbsp;verify the accuracy of the new data that you provide to us.</p> <p> <strong>- Right to deletion </strong>of your Personal Data. This enables you to ask us to delete or remove Personal Data in certain circumstances. Please note, however, that we may retain your data in certain circumstances in accordance with law, which will be notified to you, if&nbsp;applicable, at the time of your request.</p> <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&nbsp;use of your data, but we need to verify whether we have overriding legitimate grounds to&nbsp;use it.</p> <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> <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> <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> <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&nbsp;provide certain products, content or services to you. You may always be able to opt out of receiving marketing emails and/or text messages from us by clicking on the unsubscribe link which is part of the email and/or text messages you receive.</p> <p>If you wish to exercise these rights, or if you wish to revise your privacy permissions or choices please email us at: mobility_support@here.com.</p> <p>If you believe your privacy has been compromised, please email us at: mobility_support@here.com as soon as you can.</p> <p>Please note that in cases where we act as data processer with respect to your Personal Data, you must contact the relevant Partner who acts as the data controller with respect to your Personal Data, to exercise your rights.</p> <p> <strong>7.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp. Modifications to this Privacy Policy and to the Services</strong> </p> <p> <strong>What this Means.</strong> <em> 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 Data.</em> </p> <p>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 Data 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 Data, 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.</p> <p>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 Data, we will update this Privacy Policy 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.&nbsp;</p> <p> <strong>8.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp. Contacting Us</strong> </p> <p> <strong>What this Means.</strong> <em> You may contact us either via email or post mail at these addresses.</em> </p> <p>Questions or concerns about this Privacy Policy can be directed to us via email at mobility_support@here.com or at:</p> <p>HERE Global B.V</p> <p>C/O Privacy</p> <p>Kennedyplein 222 -226</p> <p>5611 ZT Eindhoven</p> <p>The Netherlands</p> <p>The Company’s Data Protection Officer can be contacted at:</p> <p>Henri Kujala</p> <p>HERE Deutschland GmbH</p> <p>Invalidenstrasse 116</p> <p>10115 Berlin</p> <p>Germany</p> <p>Email: mobility.privacy@here.com</p> <p>If you are not satisfied with the Company’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> <p>&nbsp;</p> <p>&nbsp;</p> <p>&nbsp;</p> <p>&nbsp;</p> <p>&nbsp;</p> <p>&nbsp;</p> <p>&nbsp;</p>




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