Updated: January 2020
Telenav GmbH owns and operates skobbler.com and skobbler.de and is a wholly-owned subsidiary of Telenav, Inc. As a subsidiary of Telenav, Inc., Telenav GmbH adheres to the privacy policies of Telenav, Inc. set forth below.
By “Personal Data”, we refer to data that relates to you as an identified or identifiable natural person. Personal Data includes, but is not limited to your name, your address, your telephone number including mobile telephone numbers, billing account number, Mobile Subscriber Identifier, Mobile Equipment Identifier, Network Address Identifier, IP address, your email address. Anonymous information, which we are not in a position to relate to you, does not qualify as Personal Data.
Except where this Policy explains otherwise, Telenav is the controller in relation to the Personal Data processed in accordance with this Policy. The controller is called “Telenav”, “we”, “our” and “us” in this Policy.
If you have any questions and requests relating to this Policy, including any requests you may make to exercise your legal rights in relation to your Personal Data, you can contact us via the email address email@example.com.
- Information Telenav collects and how we use it
- How we address the privacy of children
- Steps to safeguard Personal Data
- How long Personal Data is Retained
- With whom Telenav shares Personal Data
- Your rights
- Contacting Telenav
- About this Policy
1 INFORMATION TELENAV COLLECTS AND HOW WE USE IT
Use of our Telenav Platform
Depending on how you interact with us, we gather various information from different sources. Some collected information is provided directly by you (e.g., when you create an account to access our services) and other information is indirectly collected through your use of our technology, access our websites and/or use our services-- which include mapping, navigation, in car commerce and other services (collectively the “ Telenav Platform”).
The information collected through your interaction with and use of our Telenav Platform may include, but is not limited to, browser and device information, data collected through automated electronic interactions, application usage data, demographic information, geographic or geo-location or routing information, information from your vehicle sensors, statistical and aggregated information (“Other Information”). We may collect and use your Personal Data to provide you with our products and services, to process your requests or as otherwise may be necessary to perform the contract between you and Telenav, to ensure the functionality and security of our products and services, to identify you as well as to prevent and investigate fraud and other misuses.
We may also collect Personal Data and other information that you voluntarily provide. It is entirely your decision whether to provide the requested information, but certain features of our Telenav Platform may not be available if you elect not to provide the requested information (e.g. if you want to submit a request for support, but are unwilling to provide us with your name and email address).
Each time you access navigation services, your location, search and route information, including your point of origin or current location, the address of your destination, the starting time of your trip, and the route you are instructed to follow are recorded and stored locally or in our cloud database. During an active navigation session, we periodically record your current location, data from your vehicle’s sensors, and GPS heading and speed from the GPS hardware associated with your vehicle in order to provide you with your route. Our navigation services also make use of your current location or route in order to respond to your requests for nearby points of interest (such as gas stations, restaurants, shopping, etc.). We maintain a database with these locations and route information and may use such information to improve our map coverage and to provide other features that may enhance your service capabilities, functions, and your user experience. We may periodically receive your current location or route from the GPS hardware associated with your wireless device for the purpose of providing enhanced services, including traffic flow data. When your location, GPS heading and speed are used for these purposes, we remove your Personal Data, such as your phone number, prior to storing. We may share such location data in anonymized form with our third-party partners performing research and analysis about traffic conditions and road segment usage.
Scout Mobile GPS Link (including Toyota & Lexus Users)
When your mobile device's location services are being used by Scout Mobile GPS Link or other third-party applications or your mobile operating systems services, the Scout Mobile GPS application may periodically collect and store data about your current location or route along with a non-personally identifiable version of your device ID to create an anonymous profile for advertising purposes. We may share this profile with third parties for advertising purposes or to provide or make available a product or service in connection with your location or route. Additionally, this location or route data may also be used by us for anonymous traffic flow data or floating car data. For additional information about this data usage and how to opt-out, please refer to the “Contacting Telenav” section below.
When you choose to use your current GPS location for specifying the locale for a business finder search or obtaining a map within one of our mobile applications, we use your location or route information for the requested purpose, and then discard it. We anonymously record any search activities and results for comparative analysis. Further, we anonymously record transactions for the purpose of paying directory listing and mapping data providers.
Location Sharing (GPS Navigator, Scout Mobile GPS Link, Partner-Branded Navigator Apps)
Some versions of our Telenav GPS Navigator application, Scout mobile application, and our partnered-branded versions of our Navigator application include a location and information sharing feature that enables you to share your location or other information with another party. These location exchanges are transmitted within the application or via the internet or text messages using SMS. For example, when you create, join, or navigate to a Meet Up with the Scout application, your name, profile photo, current location and/or ETA at the Meet Up location will be displayed on a map visible by other Meet Up participants. The Meet Up and your location and/or ETA will be removed from the map visible to other participants when you delete the Meet Up. We record these location exchanges. Also, if you set up a Notification within the app, the phone numbers you provide will be automatically notified via SMS message each time you arrive at or depart from the location you select. You can turn off a Notification from within the application's settings menu.
Contact Sharing (Scout Mobile GPS Link/ Scout Mobile Application)
In some versions of our Scout and Telenav navigation mobile applications, you can allow our application to access the data stored in the address book and/or calendar on your mobile device. Our applications may use data from your address book or from your Facebook or Google+ contacts (if you signed in with a Facebook or Google+ sign-in) to allow you to search for and navigate to the addresses of your contacts, chat with your contacts within the application, or create a Meet Up within the application. Our applications may use calendar entry data to provide you with reminders about upcoming appointments and to provide navigation to the locations of your appointments. We will only access this data if you have given permissions for a particular Telenav application to do so, and you can revoke such permissions at any time by changing the settings on your mobile device.
Ford Navigation and FordPass
When you use Ford Navigation services in connected mode or the FordPass application to search for a point of interest or an address, we receive and store your unique user ID assigned by Ford, your current GPS location and planned route and/or destination information, your address or point of interest search requests and search results selections, information about your use of the location and routing search service, its performance, and your related actions and selections. We may use this information to provide, improve, and enhance our products and services. It may also be shared with Ford in aggregated, anonymized format.
GM Users of Navigation, OnStar® Connected Navigation and Connected Navigation
Your most recent destinations will be saved to allow you to easily navigate to these destinations again.
When you choose to use your current location for specifying the locale for a business finder search, or obtaining a map, we use your location information for the requested purpose, and then discard it. For OnStar Connected Navigation users, we anonymously record any search activities and results for comparative analysis.
For GM Navigation-only users, location and route information will be stored on your navigation system’s local memory. For OnStar Connected Navigation and Connected Navigation users with an active subscription who have opted-in to use connectivity, location and route information in identifiable form will be stored in our secure cloud database, until your account is deleted, to allow us to understand what actions users are taking within a session and over time so as to improve our user interface, search results, ease of use, and accuracy and to develop other features that may enhance your user experience. For OnStar Connected Navigation and Connected Navigation users, your home and work addresses, favorite places, and recent destinations may also be stored with your account information in our secure cloud database until your account is deleted.
For OnStar Connected Navigation and Connected Navigation users who have enabled the predictive navigation functionality, we will regularly receive and record your location (latitude and longitude coordinates and road edges) from your vehicle’s GPS hardware, whenever you are operating your vehicle. This data will be stored in our secured cloud database until your account is deleted and we will use such information to customize and improve your navigation and search experience and our services, for example to provide preferred brand point of interest search results, personalized routing, and commute alerts.
Accessing Telenav Map & Data Services Through 3rd Party Applications
When you access Telenav map and data services through a third-party application, we receive and store your location and route information from your device along with any address or point of interest search requests along with associated destination location and route information. We maintain a database with locations, routes and search information and may use such information to improve our map coverage and to provide other features that may enhance your service capabilities, functions, and your user experience. Such data does not contain any Personal Data.
Scout Marketplace Application
Additional Processing of Data
Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Data. For example, we may aggregate Personal Data to calculate the percentage of users in a particular country. If we combine Other Information with Personal Data, we will treat the combined information as Personal Data. The processing of such personal data is necessary for the performance of a contract with you, or part of your undertaking to enter into a contract with us. In case, the information is unrelated to any (future) contract, we process the Personal Data based on our legitimate interests to provide you with information about Telenav and also to keep our systems safe. We keep all information collected confidential and will only use the information for the particular purpose it was originally collected for. We will seek your specific permission for any additional use. We do not barter, trade, or sell access to your information without your specific consent.
Cookies, Web Beacons, and Similar Technologies on our Telenav Platform
When you access, use, register on and/or fill out a form on one of our Telenav websites or (including telenav.com, scoutgps.com, scoutgpslink.com, skobbler.com, skobbler.de or chatbaka.com), or register for services using the Telenav Platform, we collect data from you in several ways. The types of Personal Data collected include: cookies, usage data, your name, your company name, your email address, your phone number, and other contact information.
The collected information is also disclosed to and processed by Google and is used to enable features including but not limited to remarketing and display advertising. We use remarketing, display retargeting and search retargeting with Google Adwords to advertise online and third-party vendors, including but not limited to Google, show our ads on our Telenav Platform across the Internet. We also use Google Analytics to optimize our Telenav Platform. Telenav and third-party vendors, including but not limited to Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads about our products and services based on your past visits to our Telenav Platform or your search history. These features are solely for purposes to allow us to maintain the interests of previous visitors and deliver advertisement content specifically targeting the visitors' previous interests and searches. You may opt out of such advertising using the Google Ads Preference Manager or obtain additional information available about Google's Remarketing Privacy Guidelines, Policies, and Restrictions and how Google uses data when you use their partners' websites or apps.
Also note that we do not have a system to comply with Do Not Track requests at this time, unless required by applicable laws or regulations.
Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Data. For example, we may aggregate Personal Data to calculate the percentage of users in a particular country.
If we combine Other Information with Personal Data, we will treat the combined information as Personal Data.
Legitimate Interests for Processing Data
We will use data collected from you for the following purposes:
- To respond to user inquires and customer support requests; and
- To send emails or to contact you by other means regarding your account and/or to inform you about our products and services that may be of interest to you.
We rely on either the legitimate interests pursued by us or by third parties, or on the necessity to perform a contract you a part of, or your consent, for the processing associated with the previously mentioned purposes.
Register/Information Related to Your Account
We may collect and store Personal Data about you when you register to become a customer of our services, access or use our products and services and when you otherwise transmit such information to us via our Telenav Platform or by email. For instance, to maintain and/or verify your account we may collect and store in a database your name, nickname(s), mobile phone number, mobile phone model, wireless carrier, and in certain circumstances your email address, device ID/number. In certain versions of our applications, you may also be given the option to provide a profile photo.
When you choose to access our Telenav Platform through a Facebook log-in, we collect your name, email, token ID and user ID with your permission. Your name will be displayed and stored within our application and your email will be stored to provide future access to our Telenav Platform. We may use this email to contact you regarding your account and/or to respond to any inquiry or feedback you submit from within our applications. If you want to revoke authorization for our Telenav Platform to interact with your Facebook account, you can sign out of Facebook from within the Services’ settings menu, remove the Telenav Platform from the list of permitted Apps, or turn off the Platform for Apps, Plugin and Telenav Platform from the Settings menu for your Facebook account.
When you choose to access one of our Telenav Platform through a Google Sign in, we collect your email and basic profile information with your permission, which will be stored to provide future access to our Telenav Platform. We may use this email to contact you regarding your account and/or to respond to any inquiry or feedback you submit from within our Telenav Platform. If you want to revoke authorization for our Telenav Platform to interact with your Google account, you can sign out of Google from within the Services’ settings menu.
We may also use the information that we collect about you to manage your Telenav account and provide you with customer support, perform research and analysis about your use of our products and services, to inform you from time to time by email, Short Messaging Service (SMS) message and/or within our Telenav Platform about products or services similar to those you are already using, unless you inform us that you opt out from receiving such communications from within the email, SMS message or the Telenav Platform. We may share the information we collect about you in anonymized format and your usage activity with our third-party partners for the purpose of performing research and analysis about users of our products and services.
For users of Ford Navigation or the FordPass application, we will not receive your Ford username or PIN. Telenav will receive from Ford a unique user ID that does not contain any Personal Data. Your user ID will be stored and used to identify you whenever you make a search request.
Contact Our Customer Service Representatives/In-App Feedback
We may use your email address to contact you with regard to your account, such as to communicate that it is about to expire or to confirm any change to your phone number, and to respond to any inquiry or feedback you submit via our Telenav Platform by email or from within any of our applications. You may opt-out of receiving such communications using the link provided within the email.
Additionally, if you provide feedback regarding a routing or map issue within our Telenav Platform, we may share your comments and anonymized data about your location and route with the OpenStreetMap community for purposes of improving OpenStreetMap data.
Accessing Our Telenav Platform
When you use our Telenav Platform, you will be asked to provide certain information. We may use your mobile phone number as your account number and if you consent may provide you with a verification code via SMS message. We may also assign you a separate and unique ID number as your account number. Your account number may be stored and used to manage your account and provide you with customer support, perform research and analysis about your use of our Telenav Platform, to inform you from time to time by email, SMS message and/or within our Telenav Platform about products or services that you are similar to those you already use, unless you inform us that you opt out from receiving such communications from within the email, SMS message or the Services.
Some of our services or products also allow you to create a personal identification number (PIN), which we store in our database, for the purpose of you logging into your account. In some cases, this PIN is generated for you automatically on your wireless device and cannot be altered.
Some of services or products also give you the option of providing us with your home and work addresses, which we store in our database, to enable you to access readily other features of our Telenav Platform.
On some versions of our Telenav Platform you can also create a list of "favorite" addresses that can include your home and work addresses. We store these addresses in our database so that you can access them from your mobile device, and so that should you change devices, this collection of addresses will still be available to you.
When you participate in a Telenav promotion, such as a sweepstakes or contest, we may ask you to provide your name and email address, and possibly other information such as your mailing address and telephone number.
We store this information in our database and will use it to communicate with you about the promotion. We may also use your email address from time to time to inform you about our products and services we think will be of interest to you and will seek your consent to the extent required.
Request for Information
If you use or link to public forums such as social networking services, blogs on Telenav or non-Telenav website, internet bulletin boards, or chat rooms, be aware that any Personal Data you submit can be read, collected, or used by other users of these forums, including to send you unsolicited messages. Telenav cannot prevent the distribution and use of such information by other parties.
Other Information and Submissions
When you use the voice command or entry features within Scout, Telenav Navigator or FordPass/Lincoln Way mobile applications, we record your audible utterance (what you said). We use this information to adjust speech recognition performance parameters to improve accuracy.
We will also collect information relating to your use of and the performance of our applications, including the state of your device at the time of an error or issue with the application, and such information is disclosed to and processed by third-party providers, including but not limited to Crashlytics, for purposes of collecting information about errors or issues within our applications so we may improve our applications.
We may retain any data you provide to us in an email inquiry, for the purpose of tracking the types of questions we receive.
We collect Personal Data about you when you submit survey responses, a job application or resume. We will use such information only for the stated purposes.
Information from Other Sources
We may obtain information about you from outside sources and add to it or combine it with your Personal Data. For example, we may collect demographic and marketing data about you from third parties for marketing research and analysis to improve our products/services, obtain updated address information from our shippers, or collect information from other vendors that promote and distribute our products through their own brands.
Other Websites or Telenav Platform
Legal Basis for Processing Personal Data
Telenav processes your personal data in accordance with the applicable data protection laws. We therefore process your personal data for the following legal grounds:
- for the performance of a contract to which you are a party or in order to take steps at your request prior to entering a contract
- for the purposes of our legitimate interests or those of a third party
- for compliance with a legal obligation to which we are subject
- your consent.
Information on U.S. Wireless Devices
The Telenav software (and any upgrades, modifications, or additions thereto) that is factory installed or downloaded to, and resides in, your car or upon your U.S. wireless device, retains your manually entered account number and PIN, or reads it from the device. Having your carrier change the assigned phone number for your wireless device does not change the account number we maintain with regard to that device, which will result in your device not being able to access your Telenav account established using the previous phone number. If this happens, please contact Telenav Customer Support via email at firstname.lastname@example.org.
2 HOW WE ADDRESS THE PRIVACY OF CHILDREN
We recognize that we have a special obligation to protect personal information obtained from children. We will not knowingly request or collect personal information from any child, or process such information, without prior verifiable parental or legal guardian consent. If, however, you authorize a child to use our Telenav Platform, including by providing them a device associated with your Telenav service, any Personal Data associated with such use will be treated as your information in accordance with this policy. Telenav encourages parents to be involved in the online activities (including wireless Internet browsing) of their children to ensure that no information is collected from a child without parental or guardian consent. For the purpose of this Policy, a child means any individual who is under the age of 13 (or the minimum legal age to consent to the collection and processing of personal information where this is different under applicable law).
If you are under the age of 13, please do not submit any personal information through the Telenav Platform. If you have reason to believe that we may have accidentally received information from an individual under age of 13, please contact us immediately at email@example.com.
3 STEPS TO SAFEGUARD PERSONAL DATA
We and our employees understand the need for your privacy, and we maintain reasonable and appropriate security procedures to protect your information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data. For instance, Telenav limits access to Telenav systems that store such information to authorized personnel. Telenav also employs the Secure Sockets Layer (SSL) protocol to protect your Personal Data, therefore transmissions are secured by using encryption.
While Telenav maintains a multitude of security measures to prevent unauthorized access to or disclosure of your Personal Data, no security measures are absolute or wholly guaranteed. We recommend you protect yourself against any unauthorized access to your account, implicitly to your password, which you are responsible for keeping it confidential and not share it with anyone.
If required by law, we will notify you if it determines there were unauthorized acts that violate the law or this policy, or other security breaches.
4 HOW LONG PERSONAL DATA IS RETAINED
We will retain your Personal Data for no longer than we believe is necessary for the purposes outlined in this Policy. The length of time we retain Personal Data, 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, we retain your Personal Data related to managing your account (such as name, email address, account content and preferences) for as long as they are retained by you within your account. We may typically maintain other data, such as records of your activity within the application, only for a short period before being anonymized or pseudonymized. We may also retain your Personal Data for other purposes permitted under applicable law, including, for example, defense of any legal claims. Additional information may be provided based on what is applicable to the product or service you are using. You may contact the firstname.lastname@example.org to obtain additional information about retention of your Personal Data.
5 WITH WHOM TELENAV SHARES PERSONAL DATA
Telenav companies and authorized third parties
We may share Personal Data with our affiliates and subsidiaries, partners, vendors or agents working on our behalf for the purposes described in this Policy. For example, we may hire companies to assist with protecting and securing our systems or services and to support the purposes described in Section 1. We may share Personal Data with the following categories of recipients: hosting providers, cloud SaaS software providers for employee recruiting, payment providers, email service providers, security and authentication providers, user support providers, advertising providers, marketing providers, analytics providers.
Any vendor or agent that we retain must comply with our data privacy and security requirements and this Policy and are not allowed to use Personal Data they receive from us for any other purpose. Like us, they will never barter, trade, or sell access to your Personal Data. We remain responsible and liable under data protection laws if third-party agents we engage to process Personal Data on our behalf do so in a manner inconsistent with the applicable data protection laws, unless we prove that we are not responsible for the event giving rise to the damage.
International transfers of Personal Data
Our products and services may be provided using resources and servers located in various countries around the world. Therefore, we or our partners, vendors or agents may transfer your Personal Data across international borders outside the country where you use our Telenav Platform, including to countries outside the European Economic Area (EEA) that do not have laws providing specific protection for Personal Data or that have different legal rules on data protection, for example, the United States of America. In such cases we ensure that, prior to any transfer, there is a legal basis for such a transfer and that adequate protection for your Personal Data is provided as required by applicable law, for example, by using standard contractual clauses approved by the European Commission or relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures. You may contact the Telenav privacy team at email@example.com to obtain additional information about the safeguards we take in connection with these transfers.
We will comply with any subpoenas, court orders or other legal processes for any of the information about you in our possession, and we may use such information to establish or exercise yours, ours, or others' legal rights, or to defend against legal claims. We also may be required to disclose Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Mergers and Acquisitions
If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing Personal Data to prospective or actual purchasers and their advisers, or receiving Personal Data from sellers and their advisers. In case of such disclosures of Personal Data, we will comply with all applicable privacy requirements.
6 YOUR RIGHTS
Please be informed that, in ensuring that we are responding to and processing the proper request, we will require, to the extent permitted by applicable law, proof of identity. One such means of proof, might consist of asking you to submit your request from the email address you used for creating your account. You have the following rights:
- The right to know what Personal Data we hold about you and to access it. To the extent that your request is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request.
- The right to have incomplete, incorrect, unnecessary or outdated Personal Data updated.
- The right to request your Personal Data to be erased.
- The right to object to or restrict the processing of your Personal Data, in certain circumstances. If you object, and your objection is justified, we will no longer process your Personal Data or we will adjust accordingly our processing activities. On the contrary, if the legitimate reasons described by us as a justification for the processing prevail the reasons you described, we will inform you of the reasons why we are entitled to continue with the processing of your Personal Data.
- You may object, at any time and without giving any reason, to the processing of your Personal Data for direct marketing purposes.
- The right to data portability, under certain circumstances.
- The right to withdraw your consent at any time and without giving any reasons, where the processing of your Personal Data is based on your consent. Such withdrawal shall have no impact to the data processing activities that have taken place before the withdrawal or to any other further processing activity of your Personal Data which is justified by an existing legal justification. Please note if you withdraw your consent, we may not be able to continue providing services to you.
- The right not to be subject to any automatic individual decisions which produces legal effects on you or similarly significantly affects you.
- The right to lodge complaints before the competent data protection authorities. The authority responsible for Telenav is the National Supervisory Authority for Personal Data Processing, Bucharest, 28-30 General Gheorghe Magheru Boulevard, District 1, PC 010336, Romania.
7 CONTACTING TELENAV
4655 Great America Parkway, Suite 300
Santa Clara, CA 95054
Phone: (866) 686-0192
If you are a resident of a European Union member state or the European Economic Area you may direct your questions or complaints by sending an email to firstname.lastname@example.org.
8 ABOUT THIS POLICY
Telenav is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Changes to this Policy
We may from time to time make changes to this policy. Any changes will be published on our policies page on telenav.com and will be effective as of the date of publication (which will also be noted on our website). This policy was last updated in January 2020.