Navigation — GM 2019/20 — Africa

Telenav Privacy Policy for Navigation

This Privacy Policy governs your use of the Navigation service offered by Telenav, Inc., (“Telenav”), a company incorporated in the state of Delaware in the United States and headquartered at 4655 Great America Parkway, Suite 300, Santa Clara, CA 95054, USA, for select automotive vehicles produced or distributed by General Motors Holdings LLC or its affiliates (“GM”).  In order to provide you with Navigation and related services, we collect, store, and otherwise process (both automatically and manually) certain information relating to your account, your location, and your use of the navigation services.  Please review this Privacy Policy for more detail about the information that may be collected and used in connection with your use of Navigation.

Telenav understands and respects your concerns about the use of your personal data that directly or indirectly identifies you, collected from you as a user of Navigation and/or OnStar Connected Navigation ("Personal Data"). Personal Data includes, but is not limited to, your name, home address, telephone number, email address, and VIN number. Personal Data does not include anonymous or aggregate information, which after processing cannot be associated with a specific person or entity. We believe that you should know what information about you we collect, as well as how that information is used, maintained, and, in some cases, shared. The following sets forth our privacy practices and policies, applicable to Navigation users.

You acknowledge and understand that this Privacy Policy does not apply to other Telenav products or services, our business partners or other companies that Telenav does not own or operate. For information about other Telenav products and services as well as the Telenav.com website, please visit https://www.telenav.com/legal/policies. For information on how other providers of products or services handle Personal Data you provide through other web sites or through the use of our services in conjunction with a third party, please consult their privacy policies.

A. INFORMATION COLLECTED ABOUT YOU AND OUR USE OF SUCH INFORMATION

The types of personal and other information we may collect about you are primarily from two sources: (1) information you provide; and (2) information automatically collected. How we use and maintain that information is described below. We need the information to provide you with our services. If you do not provide us with the Personal Data, we may not be able to deliver you with all functionalities.

1. Information You Provide

(a) Register/Information Related to Your Account

We receive and store Personal Data about you when you authorize GM to share that information with us or contact us by phone or email regarding our products and services.  To maintain and/or verify your account we may receive the following account information: your vehicle information.

Through Navigation, you have the option of providing us with your home and work addresses, which we store locally and/or in our database, to enable you to quickly navigate to those destinations. Through Navigation you can also create a list of "favorite" addresses and points of interest. Within Navigation you also have the option to use the Navigation settings menu to customize your experience, for example by selecting your navigation and search preferences, setting up traffic reports, editing your information, and selecting your preferred gas grade. This information is stored locally on the navigation system in your vehicle.

(b) Contact Customer Service /Feedback

GM may use your email address or phone number to contact you with regard to Navigation, such as to respond to any inquiry or feedback you submit with GM Customer Service Representatives.

If you provide feedback regarding a routing or map issue, we may share your anonymous comments and anonymized location data with our third-party map provider. Our legitimate interest is to provide a better user experience.

(c) Request for Information

When you request additional information about Navigation, the information collected through these requests may include your name, phone number, and email address. We will use this information to provide you with details about these services, and in accordance with requirements under applicable law, we may use this information to promote our services to you in the future, unless you inform us that you opt out from receiving such communications.

(d) Public Forums

If you use or link to public forums such as social networking services, blogs on Telenav or non-Telenav websites, 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.

2. Information Automatically Collected

The navigation system in your vehicle will automatically receive certain types of information, some of which may be associated with Personal Data, when you use Navigation, as follows:

(a) Information Related to Your Location and Route

Each time you access Navigation, 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 as described below. When you are in an active Navigation session, Navigation will 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. This location and route information will be stored in the local memory of your vehicle’s navigation system. Navigation will save and display your most recent destinations to allow you to easily navigate to these destinations again.

WHEN YOUR INFORMATION WILL BE SHARED OR DISCLOSED

Telenav does not sell, rent, license, distribute, transfer or otherwise share information relating to your use of Navigation with third parties except as explained in this Privacy Policy, or as otherwise required or permitted by applicable law.

Consent Given/Transaction Processing

We may disclose Personal Data about you to third parties who perform services on our behalf, so called data processors. The acceptance by you of this policy and your use of the Navigation may constitute consent to such disclosure.

Third Party Services or Third Party Service Providers

Telenav may share certain information that is not Personal Data with strategic partners that work with us to analyze usage, provide and improve products or services, or that help us market to customers, or for similar purposes, so called data processors. Information that is not Personal Data is not subject to any restrictions of use or disclosure under this Privacy Policy.

Some of the Navigation services and functionality are provided by or in conjunction with third party service providers. These third-party service providers process Personal Data on our behalf and are obligated by written agreement to process such information under the instruction of Telenav and in compliance with this Privacy Policy, applicable law, and other appropriate security and confidentiality measures. Our service providers are given the information they need to perform their designated functions on our behalf, and we do not authorize them to use or disclose Personal Data for their own marketing or other purposes without your explicit consent. Personal Data may be maintained and processed by us, our affiliates and other third-party service providers in the US or other jurisdictions.

Legal Processes

We, our affiliates and service providers will comply with any applicable subpoenas, court orders or other legal processes for information about you in our possession, and we may use and disclose Personal Data to establish or exercise your, our, 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.

Business Transfers

Information about you in our possession may be disclosed as part of a prospective or completed merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the unlikely event of insolvency, bankruptcy, or receivership in which your Personal Data would be transferred as one of the business assets of the company. Telenav does not guarantee that any entity receiving such information in connection with one of these transactions will comply with all terms of this policy.

International Users

Information that we collect about you may also be transferred among our various divisions and affiliated companies around the world, which may involve transfer outside of the jurisdiction in which you reside, including from countries within the European Economic Area (EEA) and Switzerland to countries outside the EEA. As a result, that country's courts, governments or law enforcement agencies could obtain disclosure of such information under that country's laws.

When sharing personal data with processors or affiliates within the US, we safeguard these transfers with Standard Contractual Clauses (SCCs) or other legal means. Please contact our DPO to obtain a copy of these safeguards.

C. SECURITY OF PERSONAL DATA

Telenav has implemented various adequate physical, electronic and procedural safeguards, including legal, technical and organizational measures in an effort to protect the confidentiality and security of Personal Data in our custody and under our control. For instance, Telenav limits access to Telenav systems that store such information to authorized personnel.

D. CUSTOMER REQUESTS FOR INFORMATION

Customers are entitled to request information concerning whether Telenav has disclosed Personal Data to any affiliated companies or third parties as well as to request information regarding full names and addresses of such affiliated companies and third parties and to request that such affiliated companies or third parties discontinue processing of their Personal Data. Customers are further entitled to request access to or know the location (storage) of their Personal Data under Telenav's control and to update and correct inaccuracies in such Personal Data as well as to block and delete Personal Data. You have the right to access, to rectification or erasure, to restriction of processing, and to data portability, as well as the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent before its withdrawal. To protect your privacy and security, Telenav will take reasonable steps to verify your identity before providing you access or making corrections. Good faith efforts to resolve requests to correct inaccuracies in Personal Data will be made by Telenav, except where the request is unreasonable. As stated in this Privacy Policy, Telenav will not sell or share your Personal Data with third parties for their direct marketing purposes without your explicit and separate consent. Customers who wish to request further information about our compliance with applicable privacy laws, have questions or concerns about our privacy practices and policies, or wish to rescind any prior consent to use their Personal Data for marketing purposes may contact us at support@telenav.com or write to the attention of Privacy Policy Officer, Telenav, Inc., 4655 Great America Parkway, Suite 300, Santa Clara, CA 95054, USA.

CHANGES TO THIS POLICY

Telenav may from time to time update this Privacy Policy, and we encourage you to periodically review this Privacy Policy to be informed of the latest changes. In the event that Telenav merges with, or is acquired by another company, a change to this Privacy Policy may result.

E. 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 Privacy Policy conflicts with any provision of those terms and agreements, those terms and agreements govern to the extent of the inconsistency and to the extent permitted by applicable law. In all other instances, the terms of this Privacy Policy apply.

GOVERNING LAW

By choosing to use Navigation, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the State of California, United States of America. 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.

F. UPDATE INFORMATION / REVOKE CHOICES / SUGGESTIONS / CONTACT INFORMATION

If you would like to access, update, correct or delete any information that you have provided to Telenav through your use of Navigation or to block or delete any information associated with your ID (subject to any legal obligation we may have to maintain such information), or if you have suggestions for improving this Privacy Policy, please send an e-mail to ConnectedNavCare@telenav.com or contact our Privacy Policy Officer at the contact information set out below. We will provide you with access to your Personal Data (subject to limited exceptions set out under applicable law) as well as with the right to rectify or erase your Personal Data, the right to object to the processing of your Personal Data, and the right to data portability.

You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent before its withdrawal.

G. CONTACT INFORMATION FOR INTERNATIONAL USERS

Individuals with inquiries or complaints regarding this Privacy Policy should first contact Telenav at:

Telenav, Inc.
ATTN: PRIVACY POLICY OFFICER
4655 Great America Parkway, Suite 300
Santa Clara, CA 95054
USA
Email: support@telenav.com

If you believe that Telenav has not complied with this Privacy Policy in regard to your Personal Data, you may write to the Telenav Privacy Officer at the above address. In your letter, please describe in detail — in as much detail as possible — the ways in which you believe that we have not complied with this Privacy Policy. We will investigate and verify your complaint in a timely manner.

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