Privacy Policy for Mobile Navigation Applications

Last updated: March 29, 2018

Your privacy is important to Garmin. We developed this Privacy Policy to provide you with information on how we process your personal data when you use Garmin navigation mobile applications (“apps”) for Android™ or Apple® systems, including Garmin HUD apps, Navigon apps, Navigon Select Telekom Edition apps, Garmin StreetPilot apps, the Garmin Sony Xperia Edition app, and the Garmin SmartPhoneLink app. Navigon is a Garmin brand.

Other Garmin websites, apps and products that do not include a link to this Privacy Policy and include a link to a different Garmin privacy policy are governed by that privacy policy.

“Personal data” is information relating to an identified or identifiable natural person.

To jump to a specific section of this Privacy Policy, please click on a link below:

Categories of Personal Data Processed by Garmin

Personal data that is processed when you communicate with Garmin:

When you interact with our customer support representatives via email, telephone, online or in person, we collect personal data, such as your name, mailing address, phone number, email address and contact preferences; and information about the Garmin products you own, such as their serial numbers and dates of purchase. We also may create event logs that are useful in diagnosing product or app performance-related issues, and capture information relating to the support or service issue. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives, and analyze any feedback provided to us through voluntary customer surveys.

Purpose and Legal Ground:

We use this information to provide you with customer and product support and to monitor the quality and types of customer and product support we provide to our customers. The legal ground for processing this information for these purposes is Garmin’s legitimate interests in providing quality product support.

Personal data that is processed when you use Garmin’s live location-based services:

When you use Garmin’s live location-based services, such as weather, local search, safety cameras, traffic, fuel prices, parking, LiveTrack, Foursquare, Flinc, Glympse, and multi-modal routing, within our apps, we collect personal data, such as your device identifier and location. We also may create transactional logs that are useful in diagnosing service issues.

Purposes and Legal Grounds:

(a) Garmin processes your device identifier and location for the purpose of authorizing and fulfilling requests for live location-based services. The legal ground for this processing is performance of a contract.

(b) Garmin processes your sign-in or authorization credentials for third-party service providers for the purpose of authenticating with the third party and facilitating the provision of certain live location-based services within our apps, such as Flinc or Foursquare. The legal ground for this processing is your consent. You can withdraw this consent at any time by disconnecting the third-party live location-based services within our apps.

(c) Garmin processes your location for the purpose of collecting floating car data (FCD) when using free traffic services within certain apps. The legal ground for this processing is your consent. You can withdraw this consent at any time by discontinuing use of free traffic services or purchasing a traffic subscription.

Personal data that is processed when you use Navigon Select Telekom Edition apps:

When you use Garmin’s Navigon Select Telekom Edition apps or make an in-app purchase through a Navigon Select Telekom Edition app, we collect personal data, such as your device identifier.

Purpose and Legal Ground:

We use this information to verify that you are a subscriber of the Telekom Select provider. We also use this information to process in-app purchases through the Telekom Select provider. The legal ground for processing this information for these purposes is performance of a contract.

Personal data that is processed when you opt in to marketing emails through our Cruiser app:

When you opt in to marketing communications through the Cruiser app, we collect your name and email address. We process this information to create a myNavigon account for you and register your app to that myNavigon account. The legal ground for processing this information for this purpose is Garmin’s legitimate interests in providing quality customer support and sending marketing communications relevant to your interests and purchased Garmin products and services. We also process this information to send you emails about Garmin products and services. The legal ground for processing this information for this purpose is your consent. You may withdraw your consent at any time through your myNavigon account.

Categories of Recipients of Personal Data

FCD:

We may share FCD with third parties, such as traffic service providers and partners, for purposes of improving the quality of our products and services.

Live location-based service providers:

We may need to share your location, heading direction, speed, or hashed device identifier to third-party location-based service providers, such as Cyclops, Foursquare, HERE, or other providers, for the purpose of providing the requested service. The legal ground for processing this information for this purpose is performance of a contract.

Other disclosures:

We may disclose personal data about you to others: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of our terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims.

We may also transfer your personal data to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Garmin’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that we transfer personal data will not be permitted to process your personal data other than as described in this Privacy Policy without providing you notice and, if required by applicable laws, obtaining your consent.

Transfers of Personal Data

Garmin is a global business. To offer our products, apps and services, we may need to transfer your personal data to other Garmin companies in other countries. View Garmin-owned companies. Personal data regarding individuals who reside in a country in the European Economic Area or in Switzerland is controlled by Garmin Würzburg GmbH and processed on its behalf by Garmin International, Inc.

Any transfers of personal data from Garmin companies in the European Economic Area ("EEA") or Switzerland to Garmin International, Inc. in the United States are done pursuant to European Commission approved Model Contractual Clauses.

All Garmin companies are required to follow the privacy practices set forth in this Privacy Statement.

Cookies and Similar Technologies

We collect data from users about their usage of our apps. The types of analytical information that are collected include the date and time the app accesses our servers, app version, the location of the device, language setting, what information and files have been downloaded to the app, user behavior (e.g., features used, frequency of use), device state information, device model, hardware and operating system information, and information relating to how the app functions. Garmin uses this data to improve the quality and functionality of our apps; to develop and market products and features that best serve you and other users; and to help identify and fix app stability issues and other usability problems as quickly as possible.

The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our apps so we can enhance the user experience and functionality of our apps.

Here are examples of third-party providers of analytics and similar services we currently use:

Analytics services:

  • Google: Firebase, a Google service, is used on some of our mobile apps to track the effectiveness of our marketing campaigns and advertisements. Find out more information about how this analytics information may be used, how to control the use of your information, and how to opt out of having your data used by Google Analytics.

  • Facebook: Facebook services are used on some of our mobile apps to track the effectiveness of our marketing campaigns and advertisements. You can find out more information about how this analytics information may be used, how to control the use of your information, and how to opt out of having your data used by Facebook advertising by clicking here.

  • Crashlytics (Fabric): Crashlytics is used to help us better understand usage of our apps to improve user experience and to identify and resolve the root causes of app crashes.

Privacy Policy Updates

We may update this Privacy Policy from time to time as we add new products and apps, as we improve our current offerings and as technologies and laws change. You can determine when this Privacy Policy was last revised by referring to the “Last updated” legend at the top of this page. Any changes will become effective upon our posting of the revised Privacy Policy.

We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on the Garmin websites and apps that link to this Privacy Policy.

Retention of Personal Data

We will retain your personal data contained in server log files for thirty (30) days. We will retain your personal data contained in analytics and FCD indefinitely. In addition, see below under “Your Rights” for a description of your right of erasure.

Data Controller and Data Protection Officer

If you reside in a country in the European Economic Area or in Switzerland, then your personal data collected by Garmin is controlled by Garmin Würzburg GmbH, which is located at Beethovenstraße 1a+b, 97080 Würzburg, Germany. Garmin’s EU Data Protection Officer is located at the same address and can also be reached by email at [email protected].

If you reside outside of the European Economic Area and Switzerland, then the personal data collected by Garmin is controlled by Garmin International, Inc., 1200 E. 151st St., Olathe, Kansas 66062, which you can also contact by email at [[email protected]]mailto:[email protected]).

Your Rights

If you reside in the European Union, you have the right under the General Data Protection Regulation to request from Garmin access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory authority. If you reside outside of the European Union, you may have similar rights under your local laws. For more information about these rights, please visit the European Commission’s “My Rights” page relating to GDPR, which can be displayed in a number of languages.

To request access to or rectification, portability or erasure of your personal data, or to delete your Garmin account, contact our product support team.

If you live in the European Union and you wish to exercise your right to restriction of processing or your right to object to processing, contact Garmin’s EU Data Protection Officer at Garmin Würzburg GmbH at Beethovenstrasse 1 A & B, 97080 Würzburg, Germany or by email at [email protected]. If you do not live in the European Union but you believe you have a right to restriction of processing or a right to object to processing under your local laws, please contact Garmin International, Inc. at [email protected].