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Version 1.1
Updated July 14th, 2024
This Telenav Privacy Policy ("Policy") governs your use and access of certain services, products or websites that we offer, including with or through our affiliates. The confidentiality of your personal data is one of the main concerns of Telenav Inc. ("hereinafter Telenav", "we", "us", "our") with registered office in California, 4655 Great America Parkway, Suite 300, Santa Clara. By using or accessing our services, products, website, or otherwise by interacting with us, you acknowledge this Policy and agree to be subject to it. If you do not agree to this Policy, you are not entitled to use our services, products, or website(s). You acknowledge and understand that this Policy does not apply to our business partners or other companies that Telenav does not own or operate. For information on how our business partners and other companies process your Personal Data (as defined below), please consult their privacy policies. If you do not agree with the terms of this Policy, please do not use or access our services, products, or engage in any of these activities.
We are committed to protecting and respecting your privacy. This Policy describes our approach to data protection, data privacy and data security, including our compliance with various governmental regulations and requirements, and explains why and how we may collect, store, process, and distribute your Personal Data to third parties. We also describe in this Policy your rights in relation to that information.
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, and your email address. Anonymized or Pseudonymized information, which we are not able to relate to an identifiable natural person, is not considered Personal Data.
By "Applicable Data Protection Laws", we refer to any applicable legislative or regulatory regime enacted by a recognized government, or governmental or administrative entity with the purpose of protecting the privacy rights of natural persons or households consisting of natural persons, including but not limited to: the Personal Data Protection Law B.E. 2562/2019 (“PDPL or Thailand’s Privacy Law”), Personal Data Protection Act 2012 (“PDPA or Singapore’s Privacy Act”), General Data Protection Regulation - Regulation (EU) 2016/679 (“GDPR or EU’s Privacy Law”), UK Regulation (EU) 2016/679 (“UK’s GDPR”) , Privacy Act No. 119/1988 (“APC or Australia’s Privacy Act”) and/or Privacy Act 2020 (“NZPA or New Zealand’s Privacy Act”).
All other terms shall have the meaning defined under the Applicable Data Protection Laws.
Except where stated otherwise in this Policy, both Telenav and Chang’An (Chongqing Changan New Energy Vehicles Technology Co., Ltd as the OEM) shall be defined as Independent Controllers in relation to the Personal Data each may collect, store, process and distribute in accordance with their Policy and the Agreement concluded between Parties. Except for the processing carried out by us and described herein, please consult the OEM‘s Privacy Policy for any other categories of data collected, stored or processed.
Please refer to Section 6 (“Contacting Telenav”) for questions and requests you may have relating to this Policy.
Depending on how you interact with us, we gather various information from different sources. You may provide some collected information directly to us (e.g., when you use our navigation service for route planning based on current geolocation information or search for nearby points of interest) and we may collect other information indirectly through your use of our connected navigation service (“Navigation Service”).
Categories of personal data processed.
When you use the Navigation Service on Changan vehicles in connected mode to search for a point of interest, route, or address, we receive, store, and process (i) a unique identifier assigned by Changan; (ii) your current GPS location and planned route and/or destination information; (iii) your address or point of interest search requests and search results selections; (iv) and information regarding your electronic activity such as navigation usage history, when it was used, browser used, etc.
Each time you access the Navigation Service, we may store and process the following data as well: (v) your location, search histories, historical navigation destinations and route information, including your point of origin or current location, the address of your destination, the starting time of your trip, your points of interest, favorites, your pre-set Home/Office addresses, and other similar saved data, and the route you are instructed to follow. We may store this information locally or in our cloud database.
Processing purposes
We use Personal Data to provide navigation and search services to you and may also use this information to provide, improve, and enhance our products and services. It may also be shared with Changan in an aggregated, anonymized format. You may view this Privacy Notice within the navigation system by visiting the “Navigation System Settings.”[OP1] [VX2] [OP3]
During an active navigation session, we periodically process 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 or traffic flow data. Our Navigation Service also uses your current location or route to respond to your requests for nearby points of interest (POI’s) (such as charging stations, restaurants, banks, hotels, parking lots, etc.). We maintain a database with these locations and route information and may use such information to improve our database, map coverage and to provide other features that may enhance our service capabilities, functions, and user experience, including your own user experience. We may also record your engine on/off events data to provide an accurate Home Area map data update mechanism[OP4] [VX5] [W(6] . We may store your navigation application usage data for providing a user behavioral analysis to provide better application experience purpose. For the processing foreseen in the present paragraph, Telenav shall act as independent controller and may share such location data in anonymized form with our third-party partners performing research and analysis about traffic conditions and road segment usage.
As independent controller, we may also collect, store, process and distribute Personal Data For the fulfillment of Telenav's legal obligations in the context of the services provided through Telenav, including financial, accounting, tax, and archiving obligations. We collect other information that you voluntarily provide to us, including in response to our requests. 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 support request but are unwilling to provide us with your name and email address).
Additional Processing purposes
The statistical or aggregated information we may collect and store does not directly identify a specific person, but we may derive such information 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. We may process such Personal Data as part of our performance of a contract with you or part of your undertaking to enter into a contract with us. We store all such information we collect confidential and will only process the information for the particular purpose for which we originally collected or you provided. 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.
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 based on the following legal grounds:
Your privacy is important to us, and we maintain reasonable, 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 uses the Secure Sockets Layer (“SSL”) protocol to ensure our transmission of Personal Data is secured through encryption.
While Telenav maintains various 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 by keeping your password and log in credentials confidential.
If required by law, we will notify you if it determines unauthorized acts violate the law, this Policy, or other security breaches.
Telenav has implemented policies and rules regarding the retention of personal data that fully comply with the Applicable Data Protection Laws. The retention periods are determined to serve the purposes for which they are collected and processed and are reviewed periodically to meet the standards relating to the limitation of data storage.
The length of time we retain Personal Data, and the criteria we use 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 application 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, for a short period before anonymizing such data for further authorized use. We may also retain your Personal Data for other purposes permitted under Applicable Data Protection Laws, including, for example, the defense of any legal claims. We may keep Personal Data based on what is applicable to the product or service you are using.
You may contact privacy@telenav.com to obtain additional information about our retention policies regarding your Personal Data.
Telenav affiliates and authorized third parties.
We may share Personal Data with our affiliates, 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, and 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. 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, depending on the scope of your interactions with Telenav and depending of your location. Therefore, specifically for this product, we or our partners, vendors, or agents may process and store your Personal Data as indicated under Chapter 1, within the following locations and in accordance with the following purposes related to each site:
· European Economic Area (Frankfurt, Germany) - Europe-based servers operate the cloud services and critical infrastructure for connected services related to users across Europe.
· Americas (Virginia, United States)- US-based servers manage cloud services and critical infrastructure for connected services related to users across North and South America
· Asia Pacific (Singapore) - Asia-based servers (Singapore) manage cloud services and critical infrastructure for connected services related to users in Southeast Asia, Australia and New Zealand and South Asia.
Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Policy and 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 privacy@telenav.com to obtain additional information about the safeguards we take in connection with these transfers.
Mandatory Disclosures
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 our 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.
You have specific statutory rights under the Applicable Data Protection Laws regarding the Personal Data Telenav processes about you. These are briefly explained below, and you can exercise them by using the contact information details under the “Contacting Telenav” section.
You may contact us using the following contact information:
Telenav, Inc
Attention: DPO
4655 Great America Parkway, Suite 300
Santa Clara, CA 95054, US
Phone: (866) 686-0192
Email: privacy@telenav.com
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 privacy@telenav.com.
With respect to any notice or request you may provide under this Policy, we will verify your identity or the identity of your authorized agent submitting the request on your behalf, and we will then comply with your request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Data and the risk of harm to you by unauthorized disclosure or deletion as applicable. We may require you to provide additional personal data to verify your identity before we can process your request.
Other Agreements
Telenav may enter into written product or service agreements with customers that contain specific provisions related to confidentiality, security or other handling of information. If this Policy conflicts with any provision of those terms and agreements (both US and international), those terms and agreements govern to the extent of the inconsistency. In all other instances, the terms of this Policy apply.
Governing Law
By choosing to use our Telenav Platform or otherwise provide information to Telenav, you agree that any dispute over privacy or the terms contained in this Policy will be governed by the laws of the State of California, United States of America; provided, however, (i) this Policy shall be governed by the Applicable Data Protection Laws or (ii) such other governing law as may be mandated by the jurisdiction in which you reside. Except where prohibited by applicable law you also agree to arbitrate such disputes and to abide by any limitation on damages contained in our Terms of Use, Terms and Conditions of Service, or other applicable agreement we have with you.
Telenav is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Changes to this Policy
We may update this Policy according to changes in our business functions, measures concerning the protection of Personal Data and applicable laws. If we make changes to this Policy, We will publish any changes on our website page on www.telenav.com/legal, and we will notify you through the Navigation APP in vehicle. Where changes to this Policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you may have.
Privacy is important to us, so you have the option of disabling certain types of storage that may not be necessary for the basic functioning of the website. Blocking categories may impact your experience on the website. Cookie Policy