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PRIVACY

How we use your data

Our Principles

TomTom is all about where you are and getting to where you want to be. We help you achieve more. Sometimes we'll need to know some things about you in order to help you. While we collect and use your data, we fully understand that you value your privacy.

We believe privacy is about freedom and being able to decide for yourself who uses your data and how. This is why we have established our Privacy Principles:

1. We will always keep you fully informed about your data

We make sure you understand which data from or about you we use, why we use it, how long we use it and who can use it.

2. We enable you to remain in control of your data

We consider the data from or about you to be yours. We only use it for the purposes for which you have given it to us, or for which we collected it from you. You can opt out or opt in at any time using our software and websites.

3. We protect your data

Your data is yours. We keep it that way by protecting it as best as we reasonably can to prevent it from falling into the wrong hands.


Our ten promises to you

1. We will tell you which data from or about you we use, why we use it, how long we use it, who else can use it, and where it is kept.

2. We will only use your data for the purposes we have stated to you.

3. We keep as little of your data as possible, and only for as long as we need it. When we no longer need data, we destroy it or we irreversibly anonymize it so it is no longer linked to you.

4. If we ask your permission to use your data for specific purposes, you will also be allowed to withdraw your permission.

5. If we can't reach you to ask your permission to collect and use your data and you don’t want us to use your data, just let us know and we will stop.

6. We will allow you to access and correct your data if it is linked to your MyTomTom account.

7. We will keep protecting your data against unauthorized access and accidental loss as best as we reasonably can.

8. If we engage others to use your information on our behalf, we will ensure they act in accordance with our policies.

9. We will not share your data with others without asking you for permission first, unless there is a legal obligation that prohibits us from asking.

10. We are here to answer any questions you have about how we use your data.


TomTom's policy on privacy and processing of personal data

We operate according to the privacy laws applicable in your country. Because we are based in Europe, European privacy laws also apply. These laws are considered to be the most extensive in the world. They offer a high level of protection to you by only allowing us to use your data when the strict conditions of these laws are met. Our company policy on privacy and processing of personal data reflects these laws and we apply this policy globally.

Definitions
Personal Data: any information relating to an identified or identifiable natural person ('Data subject', user); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural, or social identity;

Processing of Personal Data ‘processing': any operation or set of operations which is performed upon Personal Data, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure, or destruction.

1. TomTom will process Personal Data fairly and lawfully.

2. TomTom will collect Personal Data for specified, explicit, and legitimate purposes, and will not further process Personal Data in a way incompatible with those purposes.

3. TomTom will ensure Personal Data is adequate, relevant, and not excessive in relation to the purposes for which it is collected and/or further processed.

4. TomTom will ensure Personal Data is accurate and, where necessary, kept up to date.

5. TomTom will keep Personal Data in a form that permits identification of its users for no longer than is necessary for the purposes for which the Personal Data was collected or for which they are further processed.

6. TomTom will process Personal Data only if:
    a) the user has unambiguously given his consent; or
    b) processing is necessary for the performance of a contract to which the user is party or in order to take steps at the request of the user prior to entering into a contract; or
    c) processing is necessary for compliance with a legal obligation to which TomTom is subject; or
    d) processing is necessary for the purposes of the legitimate interests pursued TomTom, except where such interests are overridden by the interests for fundamental rights and freedoms of the user and in particular his right to privacy.

7. TomTom will avoid processing Personal Data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or Personal Data concerning health or sex life.

8. TomTom will avoid processing Personal Data related to persons under the age of 13 years.

9. To ensure fair processing of Personal Data, TomTom will inform its users of
    a) The purposes of the processing;
    b) The categories of the Personal Data concerned;
    c) The categories of the recipients of the Personal Data;
    d) How to access and rectify their Personal Data.

10. TomTom implements appropriate technical and organizational measures to protect Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access, in particular where the processing involves the transmission of Personal Data over a network, and against all other unlawful forms of processing. TomTom does this in accordance with the latest technology and the cost of their implementation, ensuring a level of security appropriate to the risks represented by the processing and the nature of the Personal Data to be protected.

11. In case processing is carried out on TomTom’s behalf, TomTom will choose a processor that provides sufficient guarantees regarding the technical security measures and organizational measures governing the processing to be carried out, and will ensure compliance with those measure. In these cases, TomTom will ensure the processing is governed by a contract binding the processor to the controller and specifically stipulating that:
    a) The processor shall act only on instructions from TomTom;
    b) The provisions of 10) are applied to the processor.

12. In principle, TomTom will process Personal Data in the European Economic Area (EEA). In those cases where Personal Data is transferred or processed outside the EEA by TomTom or on TomTom’s behalf, TomTom will ensure adequate safeguards for the protection of the privacy and fundamental rights and freedoms of individuals and with regard to the exercise of the corresponding rights by applying appropriate contractual clauses or other acceptable legally binding instruments.

13. If TomTom remotely stores information, or gains access to (any) data already stored, in a device of a user, TomTom will ensure the user involved has been provided with clear and comprehensive information about the purposes of the processing and given his or her consent. This shall not prevent TomTom from any technical storage or access for the sole purpose of carrying out the transmission of a communication over an electronic communications network, or as strictly necessary in order for TomTom to provide a service explicitly requested by the user.


Data we collect

We collect data from you or about you when you use our sites, products, and services. The specific data we collect depends on what you use and how you use it. In general, there are 3 categories of data we collect and use:

Data you provide

This is the data you enter yourself when using our sites, products, and services. This data can include, for example, your name, email address, the search terms you enter, your address and favorite locations, your phone number, any map errors reports and speed camera reports you enter, your size, weight, gender, age etc. etc.

Data collected via sensors

A lot of our products come equipped with one or more sensors or use the sensors of the devices they run on. Examples of sensors are GPS receivers, Wi-Fi or Bluetooth receivers, a camera, a microphone, G-force sensors, heart rate sensors, and touch sensitive screens. These sensors will automatically collect data when activated. Depending on the purpose for which it was captured, this data along with data that identifies you or your device can be sent to TomTom and others for subsequent use.

Metadata

This refers to any data that is collected or automatically generated while you use TomTom sites, products, or services. In many cases metadata is collected or generated as a part of using a computing device or transmitting data over computer networks, such as the internet. This data includes user interface and other device usage events, IP-addresses, unique device identifiers, Wi-Fi and Bluetooth MAC addresses, cookies, and records of computer activity.


Data we receive from others

We receive data from third parties that they have collected, under their responsibility and in accordance with their privacy policy, and shared with us. We use that data within the limits of what these third parties allow us to do with it while also adhering to our own privacy principles and policy. We receive real-time feeds of location, speed, sensors, and other vehicle and device information from, for example, mobile phone users, business fleets, and vehicles that are equipped with our online maps or traffic and travel services. We use this data only after we have made sure it cannot be linked back to you.

We also receive data from others about you when you have interacted with them, for example when you have visited their websites or used their mobile apps. This data can include IP addresses, unique device identifiers, advertising identifiers, Wi-Fi and Bluetooth MAC addresses, cookies and other records of computer activity, as well as indications of your behavior, interests, and demographic.


MyTomTom account

TomTom uses your MyTomTom account to grant you access to downloadable content, services you are subscribed to or have activated, software upgrades and sections of our website which need registration. We also use your MyTomTom account when you want to purchase additional items and to tailor our offerings to you. The way in which TomTom uses your MyTomTom account also depends on the software and device or system you use.

To create your MyTomTom account, at a minimum you need to supply your name, email address, and choose a password. TomTom advises you to keep your MyTomTom account details confidential and use a password you do not use elsewhere.

We will use your email address occasionally to send information related to the products and services registered to your MyTomTom account. We will only do this if there are updates you need to be aware of to ensure you can use your product in a safe, reliable way, without interruption or if there is a legal requirement to contact you.

Using your MyTomTom account, you can also subscribe to the TomTom News email, which provides the latest news, product information and special offers from TomTom and others we select. You can opt out of receiving the TomTom News email at any time by clicking on the appropriate link in the emails you receive.

If you want to delete your MyTomTom account, please visit tomtom.com/support.

We will not share your MyTomTom account details with anyone else, unless they work under our responsibility, according to our instructions or when explicitly and lawfully ordered to do so following due legal process.


Service management and improvements

TomTom keeps information that tells us how and when you use our services. This includes information about the device you are using and the information we receive while you use the service, such as locations, routes, destinations and search queries. TomTom uses the information for technical diagnostics, to detect fraud and abuse, to create usage reports, and to improve its services. The information is kept only for these purposes and for a limited period of time, after which it is destroyed. TomTom is unable to identify you based on this information, and will not try to. TomTom applies security methods based on industry standards to protect the information against unauthorized access. TomTom will not give anyone else access to the information or use it for any other purpose, unless explicitly and lawfully ordered to do so following due legal process.


California Privacy Rights

If your personal data is protected by the California Consumer Privacy Act (CCPA), TomTom International B.V., on behalf of TomTom business, wishes to inform you about the data categories we collect from you (including the past 12 months) and how we process your data. This privacy statement was last edited on 25 December 2019 and subject to change at any time with or without further notice. We recommend that you re-visit this information from time to time to see if anything has been updated.

This statement supplements our other privacy notifications. Each TomTom product and service collects certain categories of personal information, you can check the in-product privacy notification or relevant sections in our general online privacy statement for more information. In case another party is using our products, for example a car manufacturer, as part of a service offered to you, you can read their privacy statement for more information.

Categories of personal information

Overall, we collect the following categories of personal information:

  1. Geolocation data: 
  2. Identifiers such as your name, postal address, country, email address, account details and other unique (online) identifiers;
  3. Commercial information about your purchases such as invoices and order confirmations;
  4. Information about your internet or other electronic network activities, including information obtained via cookies and similar technologies;
  5. Audio and electronic information when you use specific product features such as voice commands;
  6. Professional information when you are registered as a visitor of TomTom offices.

Use and disclosure of your personal information for business purposes

TomTom software uses your location data to function correctly and to enable certain features. With your permission, we use your location data to send information to your device that is relevant to where you are or enabling you to use a specific feature such as our traffic services. We also use your location data to improve the quality of our products and services after making sure it can no longer be linked back to you directly. TomTom deidentifies your location data within 24 hours after you have stopped using the TomTom product or service by automatically and irreversibly destroying the data that would allow you or your device to be identified from the location data we have received. You can choose to send your location data or stop sending this information to TomTom at any time via TomTom’s product settings. If location data is stored on your TomTom device, it will be deleted when you stop sending this information to TomTom. We don’t know where you have been or who you are.

Your personal information mentioned in categories 2 – 6 will be solely used for TomTom’s business purposes, such as auditing, detecting security incidents, registration and management of user accounts, providing customer support, processing or fulfilling orders and transactions, repair and warranty services, verifying customer information, processing payments, performing analytics and research to improve the quality, safety and content of TomTom products and services.

When necessary to fulfill certain of these business purposes, TomTom shares your information with other parties such as IT hosting providers, third-party cookie providers, social media and marketing partners and other service providers that keep our products secure and performing well or manage and analyze usage of our products. We have contracts in place with these parties to process your data only for authorized purposes to deliver certain services that require them to act consistently with this statement and to use appropriate security measures to protect your personal data.

Be aware that your device operating system, your service provider using TomTom software components, or communication networks may also collect, transmit and store your personal and location information. TomTom has no influence over this. For more details you can check the statement and settings from your mobile operator, device manufacturer, supplier and other app developers. When you share certain information on social media, the social media provider will process that information in accordance with its own privacy policies. You can check these policies for more details.

We promise not to give anyone else access to your information unless we have a legal obligation to do so, for example when we are obliged by applicable law to disclose your information to governments, competent authorities and law enforcement agencies or to defend TomTom’s legitimate interests in legal proceedings. We don’t sell your personal information to anyone or otherwise disclose your personal information in exchange for money or something else of value.

Your privacy rights

You can file a verifiable request with TomTom to specifically disclose or delete your personal information. More details can be found on our privacy support page or within your TomTom account. You can also contact our customer service team for more information, contact details can be found here. In case you have appointed an authorized agent to make privacy requests on your behalf, this agent should follow the same process to provide your account details for verification. When you request TomTom to disclose your personal information, TomTom is not obliged to reidentify or link any data that is not maintained in a manner that would be considered personal information and will not do so as such. TomTom will not discriminate you for exercising these rights.