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Effective February 25, 2019
This Privacy Policy applies to the Telenav Scout Rewards & Pay App, as well as its associated Services offered by Telenav, Inc., its subsidiaries, and affiliates (“Telenav,” the "Company,” "we," "our," or "us"). By using the Scout Rewards & Pay App (the “App”) you are consenting to the collection and use of information as described in this Privacy Policy. Your privacy is important to us. The purpose of this Privacy Policy is to provide you with clear and understandable information about our privacy practices. Please note that Appendix A to this Privacy Policy includes a definitions section explaining how certain terms are used.
We are committed to protecting and respecting your privacy. This Privacy Policy describes our information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt out of a use or correct or change such information. If at any time you want to delete your information from or terminate your use of the App, or cancel your Telenav Account, please click on “Needs Help” within the App’s main menu and select “Contact Us.” Clicking this link will allow you to request that your information be deleted, or your use of the App and/or your Telenav Account canceled. Alternatively, you can simply write to us at scoutrewardsupport@telenav.com.
This Privacy Policy applies to Personally Identifiable Information ("PII") that we Process in the course of our business relating to your use of the Services that you may access while using the App. In this Privacy Policy, “ PII” means information that can be associated with an individual and that can be used to identify that individual. We do not consider PII to include information that has been anonymized or aggregated so that it does not identify an individual. We may share such anonymous or aggregated information with subsidiaries, affiliates, service providers, and other third-parties in our sole discretion. All third-parties whose responsibilities include the Processing of PII on behalf of Telenav, including its service providers, are expected to protect that PII by adherence to the terms in this Privacy Policy.
You represent that if you give us PII on behalf of someone else, the person providing the PII to you gave you consent to provide the PII to us. Likewise, if someone else gives us PII on your behalf, you represent that you gave that person consent to provide your PII to us.
If we want to use your PII in a manner different than the purpose for which it was collected, we will ask for your consent before using your PII. In connection with the provision of the services accessible using the App, PII is processed by the Company's contractual partners, service providers, or vendors on servers which may be located in the United States of America (“US”) or in other countries. In cases in which PII is Processed outside of the US, it may be Processed in countries that have less demanding data protection laws than the State in which you live, or the US in general. Where this is the case, as discussed in Section 12 below, appropriate measure will be taken to protect your PII in accordance with this Privacy Policy.
Also, we wanted to let you know that if Telenav is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, divestiture of all or a portion of its respective business or assets, a sale of company assets, or transition of service to another provider, then your information may be sold or transferred as a part of such a transaction as permitted by law and/or contract. In such an event, we will seek and obtain the transferee’s agreement to use PII in a manner that is consistent with the Privacy Policy in effect at the time such PII was collected.
If you have any questions about this Privacy Policy or our treatment of PII, please feel free to contact our Data Protection Officer at:
Telenav, Inc.
Attention: DPO
4655 Great America Parkway, Suite 300
Santa Clara, CA 95054
Phone: (408) 245-3800
Email: dpo@telenav.com
We collect information from you regarding your use of the Services in the following ways:
We will collect information from you, including PII, when you interact with the Services. For example, you provide information to Telenav and its service providers when you:
In addition, Telenav and/or its service providers may collect PII and other information through the Services such as:
We sometimes obtain PII from other sources, such as through mergers and acquisitions with other companies, as well as through commercial arrangements with Third-Party Providers, business partners, and other sources. Information we receive from third-parties is subject to your separate agreement with such third-parties, unless you enter into a separate agreement with us or otherwise give your permission to use such information. The Company may merge information we receive from third-parties with PII and any other information we have collected or will collect subject to such limitations.
Some elements of Telenav’s Services such as events, ads and offers may be co-branded and offered in conjunction with one or more Mobile Merchants. In such a co-branded situation, Telenav may receive information that may include PII. If we do, that information will be treated in accordance with this Privacy Policy.
When you sign up for the App, request or use the Services, including support services, or interact with a Mobile Merchant in the Mobile Rewards Marketplace, we may collect some or all of the following information:
We use location detection technologies to determine your approximate location. When you use the Services, we automatically collect and store certain information in activity logs such as details of how you used the Services, and device identifiers that are automatically assigned to your device when you access the Internet or your mobile carrier service.
Our Services include a unique application number that is not associated with your account or you. This number and information about your installation may be sent to us when you install or uninstall an app or when that app periodically contacts the servers that provide our services (for example, to request automatic updates to the software). Using the unique application number, we will automatically collect additional information about you, your use of your device, and the Services you utilize on your device such as:
We use information we collect to: conduct business and improve the effectiveness of our Services; develop new products and Services; provide information and support for the Services; conduct research and analysis, including focus groups and surveys; better understand your needs and interests; personalize communications and advertising/offers; promote a quality experience for users of Services; and to perform other business activities related to the Services as needed or as otherwise described in this Privacy Policy.
When you send email or other communications to us, including for support services (scoutrewardsupport@telenav.com), we may retain those communications in order to process your inquiries, respond to your requests and improve our Services. When you send and receive SMS messages to or from one of our Services that provides SMS functionality, we may collect and maintain information associated with those messages, such as the phone number, the wireless carrier associated with the phone number, the content of the message, and the date and time of the Transaction. We may use your email address to communicate with you about our services.
We will use your PII and other information to:
We may share or disclose your PII and other information as follows, and for these limited purposes:
Anonymized or aggregated information is not PII, and Telenav may use such information in a number of ways, including research, internal analysis, analytics, and other legally permissible purposes. We may use PII and other information about you to create anonymized and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device(s) you use to access the Services, or other classifications of the anonymized and/or aggregated information that we find useful. Anonymized and aggregated information are used for a variety of functions, including measuring user interest in using the App, patronizing particular merchants, using the Mobile Rewards Marketplace, collecting and using Rewards, as well as using various features of the Services and App. We may share this information with third-parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you specifically.
We may share any information we receive with Mobile Merchants, vendors and service providers. In addition to providing Services in the Mobile Rewards Marketplace, the types of service providers to whom we entrust PII include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment Processing; and (iv) customer service activities.
We may share PII with service providers, merchants providing goods or services to you, and business partners (taken together “business partners”) for our and their respective business purposes, or to provide you with products or Services that you have requested. We may also provide PII to business partners with whom we may jointly offer products or Services, or whose products or services we believe may be of interest to you. In such cases, our business partners’ name will appear along with Telenav’s name. We require our business partners to agree in writing to maintain the confidentiality and security of PII they maintain on our behalf and not to use it for any purpose other than the purpose for which we or you provided it to them. Additionally, before we use PII for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the individual is otherwise required by law or contract, we will follow the law and endeavor to comply with such a contract.
We do not track your activities on other mobile applications. However, in the event the Services associated with the App are embedded in or otherwise accessed through a Mobile Merchant’s mobile app or other third-party mobile app, we will track your Mobile Services activities. We do not allow Third-Party Providers or other third-parties with whom we have agreements to track your activities across different mobile apps when you use your Telenav Account. We may share information with software companies that enable your mobile device including app stores..
There are certain elements of PII that you must provide to us in order to use the basic Payment Account Transaction functionality Services and Telenav Scout Rewards Services. If you are not provided with an opt-out choice for the particular use of PII, then we have determined that such PII must be provided by all App users for that particular Transaction functionality or for the Services. If you are provided with a choice to opt-out of collection of certain PII, we have determined that such PII is not necessary to provide the basic Transaction functionality or Services, but may be necessary to provide certain additional Services. For example, if you opt-out of sharing geo-location services that enable us to send you location based relevant advertising and offers, you will still be able to conduct Payment Account Transactions, but you will not receive any advertising or marketing offers or coupons from Mobile Merchants in your vicinity.
We have also determined that an App user may opt-out of the collection of some PII, and the result will be that while a particular Service or feature may be utilized, it will not be utilized in an optimal manner. For example, if you opt-in to receive relevant advertising and offers, but you opt-out of sharing your mobile device location information, you may receive advertising and offers based upon your interests and prior purchases, but you will not receive advertising and offers based upon your current location or proximity to a particular Mobile Merchant.
We have put in place appropriate administrative, technical and physical safeguards to (i) protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data, and (ii) maintain data security and correctly use the information we collect. Unfortunately, no system can be 100% secure. Although we do our best to protect your PII, we cannot guarantee the security of your PII. Any transmission of PII is at your own risk. We are also not responsible for the circumvention of any of the application's privacy settings or security measures.
By using the Services or providing PII to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Telenav App and associated Services. If we learn of a data security incident, we may attempt to notify you electronically by sending you an email. You may have a legal right to receive such a notice in writing.
When you use one or more of our Services, we make good faith efforts to provide you with access to your PII and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before Processing such requests, and we may decline to Process requests where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup drives), or for which access is not otherwise required.
Before we provide access to any data, including PII, or make any changes to it we will ask you to verify your identity or provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. We may keep a copy of information for our records. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Your right to review, update, correct, and delete your PII may be limited, subject to the law of your jurisdiction of residence: (i) if your requests are abusive or unreasonably excessive, (ii) where the rights or safety of another person or persons would be encroached upon, or (iii) if the information or material you request relates to existing or anticipated legal proceedings, or (iv) providing access to you would prejudice on-going legal negotiations or an investigation of possible unlawful activity. Your right to review, update, correct and delete your information is also subject to our records retention policies and applicable law, including any statutory retention requirements.
We limit employee access to PII to those employees with a business reason for knowing the information. We regularly conduct training sessions and otherwise educate our employees, so they understand the importance of confidentiality and privacy, especially when handling another party’s PII. We will take appropriate steps, including where necessary, disciplinary steps, to enforce our employees’ privacy responsibilities.
We may access, preserve, and disclose your PII, other account information, and content, if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal processes, such as a court order or subpoenas; (ii) respond to your requests; (iii) protect Telenav’s, ours’, or others’ rights, property, or safety; (iv) to enforce Telenav policies or contracts; (v) to collect amounts owed according to the Service used in the Mobile Rewards Marketplace; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
California law permits residents of California to request and obtain from us once a year, free of charge, a list of the third-parties to whom we have disclosed their PII (if any) for their direct marketing purposes in the prior calendar year, as well as the type of PII disclosed to those parties. We do not share your personally identifiable data with third-parties outside of the Mobile Rewards Marketplace for the third-parties’ direct marketing purposes unless you provide us with consent to do so.
Use of our Services is only available to individuals who are 18 years of age or older.
To be clear, our services are not intended for or directed to anyone under the age of 18. We do not knowingly collect PII from anyone under 18 years of age.
Because we do not knowingly collect PII from anyone under 18 years of age, we also do not knowingly collect PII from children under 13 (and 16 in some jurisdictions). If, however, you authorize a child to use our Services by using the Telenav App by providing them with a device associated with your Telenav Account, any Personal Data associated with such use will be treated as your information in accordance with this Privacy Policy. Otherwise, if our policy changes, we will obtain consent from a parent or guardian before knowingly collecting data from anyone under the age of 13, or 16 as may be dictated by jurisdictional laws. If we learn we have collected or received PII from an underage child without verification of parental or legal guardian consent, we will delete that information. If you believe we might have any information from or about a child under 13 (or 16 according to the jurisdiction), please contact our Data Protection Officer right away at dpo@telenav.com.
We endeavor to only collect PII that is necessary for the purposes for which they are collected, and to retain PII no longer than is necessary for such purposes. To that end, we retain the PII we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
If you have any questions about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact Telenav by email at dpo@telenav.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.
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 inconsistency. In all other instances, the terms of this Privacy Policy apply.
By choosing to use the Telenav App, including to establish a Telenav Account, and interact with Mobile Merchants in the Mobile Rewards Market Place and/or use associated Services, 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, without giving effect to its conflict of laws provisions.
Unless prohibited by applicable law, you further agree that any dispute, claim or controversy arising out of or relating to this Privacy Policy, the App, or its associated Services, shall be settled by independent arbitration involving a neutral arbitrator and administered by the American Arbitration Association. The arbitrator shall apply the Commercial Arbitration Rules of the American Arbitration Association, and the judgment upon the award rendered by the arbitrator may be entered by any court having jurisdiction. Note that there is no judge or jury in an arbitration proceeding and the decision of the arbitrator shall be binding upon both parties.
If for any reason a matter cannot be arbitrated, you agree to venue in a court of competent jurisdiction located in Northern California.
Telenav is subject to the investigatory and enforcement powers of the Federal Trade Commission.
Please note that this Privacy Policy may change from time to time. We may revise this Privacy Policy in our sole discretion, so review it periodically. This Privacy Policy may be found at https://www.telenav.com/legal/policies-privacy-scout-rewards-and-pay, and you may want to bookmark it for your convenience. If you continue to use the App to use the Services and access the Mobile Rewards Marketplace after such changes have been made, you hereby provide your consent to the changes.
If there are material changes to this Privacy Policy, Telenav will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy so that you can access and read them. The revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is being used, please write to our Data Protection Officer at dpo@telenav.com.
“Feedback” means all feedback, suggestions, and ideas you provide to us concerning improvements or enhancement to the Services. “Feedback” may also include your responses to surveys or reporting problems.
“Mobile Merchant” means a merchant that participates in the Company’s service provider’s Mobile Rewards Marketplace.
“Mobile Rewards Marketplace” means the mobile payment and rewards network developed and managed by the Company’s service provider, which includes the Scout Rewards & Pay App.
“Payment Account” means the payment type or account you load into your Account to pay for goods and services at participating Mobile Merchants.
“Personal Information” or “Personally Identifiable Information” (or “PII”) means information that can be associated with an individual person and can be used to identify that individual, and may include Feedback, User Generated Data, or any other PII necessary to participate in the Services.
“Process” or “Processing” means any operation performed on, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation, or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
“Rewards” are the Telenav Scout Rewards earned by you when you purchase goods or Services from a Mobile Merchant.
“Services” means the off-line, online or mobile products or Services offered by through Telenav’s Scout Rewards & Pay App.
“Telenav Account” means the mobile Account that you create by registering your mobile device to use the Services, and includes accounts created through the Scout Rewards & Pay App.
“Third-Party Provider” means a third-party service provider retained by the Company, and/or its service provider, whose products, services or support may be used to provide the Services, including Payment Account issuers.
“Transaction” means any sale, lease, exchange of something of value, making available, or license of any goods or services provided to you by a Mobile Merchant.
“User Generated Data” means any information generated by your use of the Services, including automatic reporting and other tools that give you the ability to create, post, and distribute various forms of content for, and in connection with, the Services, including, but not limited to: payment transaction data; pictures; photographs; videos; and other information, including content generated by you. For pictures, photographs, and videos, the User Generated Data includes only those pictures, photographs, and videos that you take through the Services, and does not include those pictures, photographs, and videos you take via the standard functions on your mobile device, or that you take through any other app not related to us, or the Scout Rewards & Pay App.
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