Telenav understands and respects your concerns about the use of your personally identifiable information, collected from you as a customer or visitor to our websites that identifies you as a specific person or entity ("personal information"). Personal information includes name, nicknames, birth date, gender, billing and shipping addresses, telephone numbers including mobile telephone numbers, social security number, last four digits of credit card numbers, credit card holder's names, credit card expiration dates, billing account number, Mobile Subscriber Identifier, Mobile Equipment Identifier, Network Address Identifier, IP address, call records, audible utterances, email addresses, personal interests, personal identification number (PIN), and if a corporate entity, may also include company name, purchase order number, and employee number and occupation. Personal information does not include anonymous or aggregate information, which after processing may not 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 Telenav customers and visitors to the Telenav websites.
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 three sources: (1) information you provide; (2) information automatically collected; and (3) information from other sources. How we use and maintain that information is described below.
1. Information You Provide
(a) Register/Information Related to Your Account
We collect and store personal information about you when you register to become a customer of our services, and when you otherwise transmit such information to us via our applications, the internet (including partner websites) or by email. For instance, to maintain and/or verify your account we collect and store in a database your name, nickname(s), billing address, email address, mobile phone number, or device ID/number for certain devices, mobile phone model, wireless carrier, and in certain circumstances the last four digits of your credit card number, credit card holder's names, and credit card expiration dates.
We use your name, billing address, and credit card number for the purpose of billing you for our services, and other services offered from within certain Telenav products, 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 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 application. 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 application to interact with your Facebook account, you can remove the application 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 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 application. 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.
We may also use the information that we collect about you to manage your 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 application about products or services that we think will interest you, unless you inform us that you opt out from receiving such communications. 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.
(b) Contact Our Customer Service Representatives/In-App Feedback
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.
Additionally, if you provide feedback regarding a routing or map issue within one of our applications, we may share your comments and anonymized data about your location and route with the OpenStreetMap community for purposes of improving OpenStreetMap data.
(c) Accessing Our Services
When you use any of our services, including when you use a mobile device equipped with one of our services, you will be asked to provide certain information. We may use your mobile phone number/device ID number as your account number so that when you access our services for instructions or interact with our automated voice entry system, we can use caller ID to map your phone number to your account number. We may also assign you a separate and unique ID number, which may be stored and used to manage your 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, SMS message and/or within our application about products or services that we think will interest you, unless you inform us that you opt out from receiving such communications.
As a customer of Telenav, you may also 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.
As a customer of Telenav, you also have the option of providing us with your home and work addresses (to the extent they differ from your billing address), 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, and that you may edit on our website, or on your mobile device. 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.
(d) Third Party Applications
When you participate in a Telenav promotion, such as a sweepstakes or contest, you will typically 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.
(f) Request for Information
(g) 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 information 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.
(h) Other Submissions
We collect personal information about you when you submit survey responses, a job application or resume.
2. Information Automatically Collected
We automatically receive certain types of information, some of which may be associated with personal information, when you visit our websites or use our products and services.
(a) Information Related to Your Location and Route or Other User Content
Each time you access the Telenav GPS Navigator™ or Scout® service or our partnered branded versions of GPS Navigator services, we record your 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. 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 keep such information indefinitely 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 information, 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.
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 an anonymized version of your device IDs to create a profile 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, 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 services 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, and may keep such information indefinitely.
Additionally, in some versions of our 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 keep such information indefinitely 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 information, such as your phone number.
(b) Cookies, Web Beacons, and Similar Technologies on our Websites
When you visit one of our websites (including telenav.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:
Our websites may collect data about your activity and some user identifying information, including personal information. 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.
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.
(c) Information related to your personal interests for particular advertisements
When you search for a Point of Interest or address within our Scout applications or our partnered branded navigation applications, we may share your search and location data with our third party partners in order to provide you with more relevant advertisement results within the application. The information we share is de-identified so that it does not contain any personally identifying information, such as your name, phone number or email address.
When Thinknear by Telenav has the opportunity to serve an ad to you on a third party mobile site or mobile application, we may receive information about your device and location from third party ad exchanges and/or mobile publishers. This information does not enable us to personally identify you by name, phone number, email address, or other similar means, but may include your device ID, your IP address and the geo-location of your device at the time the advertisement was served. This information is provided so that we can improve the relevance of the ads we serve to you. Any such information is shared in accordance with the third party’s privacy policies and subject to their terms and conditions. We do not use the information they provide to us for any purpose other than serving you with interest-based ads on behalf of our advertising partners.
We may also obtain Precise Location Data from your use of Telenav applications (and certain other third party location based applications and use that location data) about your “geohistory”, which is the geo-location of your mobile device over time along with an anonymized version of your device IDs to create a profile. Additionally, in order to create a profile, we may use data about your location and online activity and interests, including things like real-world category types you visited (e.g. Shopping Mall), mobile apps with which you engage, information collected by our inventory partners and other third parties and shared with us. This will involve the use of your device ID and will not include any data that personally identifies you by name, phone number, email address, or other similar means,
If you would like to opt out of the use of data for geohistorical-based and interest-based advertising by Thinknear by Telenav, please contact us at firstname.lastname@example.org or click here and follow the instructions provided.
(d) Other Information
When you use the voice command or entry features on our services, 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.
3. Information From Other Sources
We may obtain information about you from outside sources and add to it or combine it with your personal information. For example, we may request credit information when you initially subscribe for service, 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.
WHEN YOUR INFORMATION WILL BE SHARED OR DISCLOSED
Consent Given/Transaction Processing
We may disclose personal information about you to third parties with your consent. Consent is sometimes implicit, as in the disclosure of personal information to third-parties who complete transactions or perform services on our behalf. For example, we routinely provide your name, billing address, and credit card information, along with the amount to be charged, to the bank that processes your credit card for billing purposes.
To the Primary Account Holder
We may disclose personal information of an account user to the primary account holder (the party financially responsible for the account). If a business, governmental agency, or other individual obtains service for you, that entity or individual is our customer, and we may provide personal information about you, or your use of the service to them or others at their direction.
Third Party Services or Third Party Service Providers
If you take advantage of a third party's services or products offered through the use of our services, we may disclose your personal information to such unaffiliated third parties. These entities may use this information that you provide in the course of your use of Telenav's services (including your name, nicknames, telephone numbers, audio files, and email and mailing addresses) to promote their products and services to you. Any such personal information that a third party uses will be subject to their applicable privacy policies.
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.
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 information 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.
INFORMATION ON WIRELESS DEVICES
The Telenav software (and any upgrades, modifications, or additions thereto) that is factory installed or downloaded to, and resides upon your 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 care.
SECURITY OF PERSONAL INFORMATION
Telenav has implemented various physical, electronic and procedural safeguards to protect the confidentiality and security of personal information under our control. 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 information when you bill on our website. While Telenav maintains a multitude of security measures to prevent unauthorized access to or disclosure of your personal information, 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. Telenav will maintain your personal information for as long as a business need exists, or as required by applicable laws, regulations, or government orders. When we dispose of personal information, we use commercially reasonable procedures to erase or render it unreadable.
Telenav will not knowingly request or collect personal information from any person under 13 years of age 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 information 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.
CHANGES TO THIS POLICY
UPDATE INFORMATION / REVOKE CHOICES / SUGGESTIONS / CONTACT INFORMATION
CONTACT INFORMATION FOR INTERNATIONAL USERS
Telenav has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Telenav, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
BBB EU Safe Harbor Web: www.bbb.org/us/safe-harbor-complaints E.U. Data Protection Authority (E.U. DPA) c/o United States Council for International Business 1212 Avenue of the Americas New York, NY 10036 Telephone: (212) 354-4480 Fax: (212) 575-0327