Last updated: November 5, 2018
This Privacy Policy (“Policy”) governs your use of certain services, products or websites offered by Telenav, Inc. ("Telenav"). By using our services, products, websites, or otherwise by interacting with us, you acknowledge this Privacy Policy. 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 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. If you do not agree with the terms of this Policy, please do not engage in any of these activities.
We are committed to protecting and respecting your privacy. This Privacy Policy describes our approach to data protection and data privacy, explaining why and how we may process your personal information where we are the data controller of that information (also referred to here as "personal data"), and 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 include 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, your age, your gender, for instance. 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.
Our Data Protection Officer is responsible for responding to questions relating to this Policy, including any requests to exercise your legal rights in relation to your personal data, and can be contacted via the email address dpo@telenav.com. Our full contact details, including our representative in the European Union, are provided at the end of this policy.
On our Sites, we gather information either directly from you (e.g., when you provide certain information to us) or indirectly (e.g., through our technology).
We indirectly collect a variety of information through your interaction with and use of our Sites. This information 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 information, statistical and aggregated information (“Other Information”). The lawful basis of the processing is that it is necessary for our legitimate interests for example to study interest in our products, grow our business and inform our marketing strategy. It is also necessary for performance of a contract with you when you register to use our services via one of our websites.
When you visit one of our websites (including telenav.com, scoutgps.com, scoutgpslink.com, chatbaka.com, or thinknear.com), register on one of our websites, and/or fill out a form on one of our websites we collect data from you in several ways. The types of personal data that our websites collect by themselves or through third parties, include: cookies, usage data, your name, your company name, your email address, your phone number, and other contact information.
The data that we collect from you may be used for the following purposes:
We may employ browser cookies or similar technologies to identify the computer, mobile device, or some of our services and record your preferences and other data. We use cookies or similar technologies to evaluate how our websites, devices or applications are used and to provide continuous improvement to our services, make recommendations, and complete transactions you request. Cookies may be stored locally on mobile devices or on computer servers operated or controlled by Telenav. We may use a tracking pixel, agent or other visitor identification technology that collects anonymous data about your use of some of our services. We may also use Web beacons, also known as Web bugs, which are mostly invisible small graphic images (1-by-1 pixel), in the same color as the background of the web page or an HTML email, to monitor interaction with our websites or emails. In addition, when you visit our website our systems automatically collect your IP address and the type of browser that you use. When you browse our websites our systems log the Telenav web pages that you visit. Server log files are records of activity automatically created by the server and stored. If we combine or link cookie or Web beacons with Personal Data, we will treat the combined or linked information as Personal Data under this policy. We may employ third-parties to place advertisements about our products and services on other web sites. The use of cookies, Web beacons or other similar technologies by such third parties is governed by their privacy policies.
You may limit the automatic collection of certain information through the use of cookies by our websites by disabling the cookies using your browser options. Please be aware that disabling cookies may prevent you from using specific features on our websites.
Our websites may collect data about your activity and some user identifying information, including Personal Data. This collected information is 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 sites across the Internet. We also use Google Analytics to optimize our websites. 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 website 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' sites or apps.
Additionally, in connection with our thinknear.com website we use a marketing automation tool called Marketo® to handle various marketing tasks, for example but not limited to, contacting visitors to thinknear.com who provided their contact information and requested additional information. HubSpot's software uses cookies to track thinknear.com visitors and contacts. You can read more about Marketo's Privacy Policy and opt-out options here.
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.
We also collect Personal Data and other information that you voluntarily provide. It is entirely your decision to provide the requested information. However, certain features of our Sites may not be available in this case. Example include submitting a request for support in our community portal or registering to receive one of our newsletters.
This processing 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 to keep our systems safe.
We keep all information collected directly confidential, and will only use the information for the particular purpose it is collected for. We will seek your specific permission for any additional use. You may choose to have this information removed at any time. We will never barter, trade, or sell access to your information without your specific consent.
For your convenience, this website contains links to other websites, including some websites administered by Telenav or administered by other companies on behalf of Telenav, as well as to websites unrelated to Telenav.This Privacy Policy does not apply to non-linked websites. Each website should be checked for its own privacy policy.
On our navigation services, we gather information either directly from you (e.g., when you provide certain information to us) or indirectly (e.g., through our Site’s technology).
We indirectly collect a variety of information through your interaction with and use of our services. This information 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 information, statistical and aggregated information, location and route information, including your point of origin (which may be your then-current location), the address of your destination, the starting time of your trip, and the route you are instructed to follow (“Other Information”). In addition, when you use our connected navigation services our systems automatically collect your IP address and information about the type of device that you use. Server log files are records of activity automatically created by the server and stored. The lawful basis of the processing is that it is necessary for performance of a contract with you and also for our legitimate interests to study use of our products and make improvements.
We record your current location when your wireless device requests a rerouting (which occurs, for example, when you deviate from the specified instructions). 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 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 strip it of 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.
For Scout mobile application users, when your mobile device's Location Services are being used by Scout or other third party applications or your mobile operating systems services, the Scout application may periodically collect and store data about your current location along with a non-personally identifiable version of your device ID to create an anonymous profile for advertising purposes. This profile may be shared with third parties for advertising purposes. For additional information about this data usage and how to opt-out, please see below regarding geohistorical-based and interest-based advertising. Additionally, this location data may also be used by us for anonymous traffic flow data or floating car data.
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 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.
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.
Additionally, 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 for 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.
When you access Telenav map and data services through a third party application, we receive and store your location information from your device along with any address or point of interest search requests along with associated destination location information. We maintain a database with locations 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, such as your phone number.
When you use Ford Sync3 Navigation 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 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.
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.
We also collect Personal Data and other information that you voluntarily provide. It is entirely your decision to provide the requested information. However, certain features of our Services may not be available in this case.
This processing 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, including promotions and newsletters, and to keep our systems safe.
We may collect and store Personal Data about you when you register to become a customer of our services, and when you otherwise transmit such information to us via our Services 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.
Where you have provided, we use your billing or PayPal account information for the purpose of billing you for certain of our services, and other services offered from within certain Telenav Services, and with your permission, may store such information for future transactions. In certain versions of our applications, you may also be given the option to provide a profile photo.
When you choose to access one of our Services through a Facebook log-in, we collect your name, profile picture, email, Facebook password and your Facebook contacts list with your permission. Your name will be displayed and stored within our application and your email and Facebook password will be stored to provide future access to our Services. 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 as described in section (b) below. If you want to revoke authorization for the Services to interact with your Facebook account, you can sign out of Facebook from within the Services’ settings menu, remove the Service from the list of permitted Apps, or turn off the Platform for Apps, Plugin and Websites from the Settings menu for your Facebook account.
When you choose to access one of our Services through a Google Sign in, we collect your email, basic profile information and Google password with your permission, which will be stored to provide future access to our Services. 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 Services as described in section (b) below. If you want to revoke authorization for the Services 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 Services about products or services that we think will interest you, unless you inform us that you opt out from receiving such communications from within the email, SMS message or the Services. We may share the information we collect about you 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 Sync3 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.
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 websites 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 one of our Services, we may share your comments and anonymized data about your location and route with the OpenStreetMap community for purposes of improving OpenStreetMap data.
When you use any of our Services, 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 Services, to inform you from time to time by email, SMS message and/or within our Services about products or services that we think will interest you, 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 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 our Services 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 services.
On some versions of our Services 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.
For users of Ford Sync3 Navigation or the FordPass application, we will receive a unique user ID from Ford. This user ID will not contain Personal Data. Your user ID will be stored and used to identify you whenever you make a search request.
We keep all information collected directly confidential, and will only use the information for the particular purpose it is collected for. We will seek your specific permission for any additional use. You may choose to have this information removed at any time. We will never barter, trade, or sell access to your information without your specific consent.
Some of Telenav's Services provide you with access to third party applications. When you enable a third party application, information collected by Telenav is processed under our Privacy Policy while information collected by the third party application provider is governed by its own privacy policy.
When you participate in a Telenav promotion, such as a sweepstakes or contest, you may be asked 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 also may use your email address from time to time to inform you about our products and services that we think will interest you, unless you inform us that you opt out from receiving such communications using the link provided within the email.
When you request additional information about one of our services either via one of our websites or via one of our partners through which our services are offered, such as a mobile telecommunications provider, information we collect through these requests include your name, nickname(s), phone number, and email address, and if you are seeking information on behalf of your company, the name of that company. We will use this information to provide you with details about our services, and 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 using the link provided within the email you may receive or by contacting support@telenav.com. To understand what a partner of ours may do with information about you in the partner's custody, you should check the privacy policy of that partner.
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.
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 collect utterances from our entire subscriber population, organize them by what was said, and then 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. Such information will be used only for the stated purposes.
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.
The Telenav software (and any upgrades, modifications, or additions thereto) that is factory installed or downloaded to, and resides 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 support@telenav.com.
We recognise 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 services or products 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).
We and our employees understand the need for user 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.
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. Telenav will make reasonable attempts to notify you if it determines there were unauthorized acts by third parties that violate the law or this policy, or other security breaches, or where otherwise required by law.
We endeavor to only collect personal data that are necessary for the purposes for which they are collected, and to retain such data for no longer than is necessary for such purposes. The length of time personal data is retained, 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, for your personal data related to managing your account (such as name, email address, and account content and preferences) are maintained for as long as they are retained by you within your account. Other data, such as records of your activity within the application, are typically maintained only for a short period before being anonymized or pseudonymized. Additional information may be provided based on what is applicable to the product or service you are using. You may contact the dpo@telenav.com to obtain additional information about retention of your personal data.
We may share Personal Data with 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 lawful purposes and legitimate interests 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 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.
Our products and 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 our services, 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 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 dpo@telenav.com to obtain additional information about the safeguards we take in connection with these transfers. A copy of the unchangeable Standard Contractual Clauses can be accessed on this page of the European Commission website.
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.
Information about you in our possession may be disclosed as part of any 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.
You have the right to access your Personal Data that we hold about you and to correct, update, amend, suppress, delete or otherwise modify any Personal Data where it is inaccurate, or has been processed in violation of the applicable data protection regulations, unless we have to keep the Personal Data for legitimate business or legal purposes. When updating your Personal Data, we may ask you to verify your identity before we can act upon your request.
You may object to the use or processing of your Personal Data or withdraw consent to use your Personal Data at any time.
You have the following rights:
Please also feel free to contact Telenav if you have any questions about this Privacy Policy or our practices, or if you are seeking to exercise any of your statutory rights. You may contact our Data Protection Officer or our EU representative using the following contact information:
Telenav, Inc
Attention: DPO
4655 Great America Parkway, Suite 300
Santa Clara, CA 95054
US
Phone: (408) 245-3800
Email: dpo@telenav.com
If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our EU representative:
EU Representative
Rivacy GmbH
info@rivacy.eu
Canadian users may also contact:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec
K1A 1H3
Toll-free: 1-800-282-1376
Phone: (819) 994-5444
Fax: (819) 994-5424
TTY: (819) 994-6591
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 (both US and international), those terms and agreements govern to the extent of the inconsistency. In all other instances, the terms of this Privacy Policy apply.
By choosing to visit this website, using the Telenav products, services or applications, or otherwise provide information to Telenav, 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; provided, however, this privacy policy shall be governed by GDPR if GDPR applies. Except where prohibited by applicable law (which may include Quebec), 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).
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 November 2018.