Privacy Policy for Navigon Fresh

Last updated: 16/07/2018

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 the Navigon Fresh application. 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 create a myNavigon account:

When you create a myNavigon account, we ask you to provide your name, email address, and country.

Purposes and Legal Grounds:

(a) Garmin processes your email address because you use your email address and your password to sign in to your account. The legal ground for processing your email address for this purpose is based on Garmin’s legitimate interest in protecting the security of your account.

(b) Garmin also processes your email address for the purpose of sending you important information about your Garmin products, apps or account, such as important safety information or material changes to this Privacy Policy. The legal ground for processing your email address for this purpose is Garmin’s legitimate interest in providing you important safety or other information about your Garmin products, apps or account or material changes to this Privacy Policy.

(c) If you provide your opt-in consent to receiving marketing information from Garmin, Garmin will also process your email address for the purpose of sending you marketing information about Garmin products and apps. The legal ground for processing your email address for this purpose is your consent. You may withdraw your consent at any time by changing your preferences in your myNavigon account or through the unsubscribe link at the bottom of our marketing emails. The marketing emails you receive from Garmin are based on your country, the types of Garmin products you have registered to your myNavigon account, the Garmin apps you have purchased or downloaded, and any subscriptions included in your myNavigon account. The legal ground for processing this data for this purpose is Garmin’s legitimate interest in reducing the number of marketing emails sent to each particular customer by selecting which customers receive a particular marketing email rather than sending every marketing email to every customer who has consented to receiving marketing emails.

(d) Garmin also processes your email address to associate it with your myNavigon account when you interact with our customer support representatives. The legal ground for this processing is our legitimate interest in providing quality customer support.

(e) Garmin processes your name to associate with your myNavigon account and greet you when you sign in. The legal ground for processing your name for this purpose is Garmin’s legitimate interest in providing a quality customer experience.

(f) Garmin processes your country for purposes of ensuring compliance with applicable laws and regulations. The legal ground for processing your country for this purpose is our legitimate interest in compliance with applicable laws and regulations. Garmin also processes your country for purposes of determining what products are available or relevant for you. The legal ground for processing your country for this purpose is our legitimate interest in providing relevant information and products to you.

Personal data that is processed when you register a product through your myNavigon account within the Navigon Fresh application:

You may choose to register your Garmin products through your myNavigon account within the Navigon Fresh application to make use of all available features. If you choose to do this, Garmin will collect unique identifiers, such as hardware ID, from the products to be registered for the purpose of associating the products with your myNavigon account. The legal ground for processing this information for this purpose is performance of a contract.

Personal data that is processed when you make a purchase through your myNavigon account within the Navigon Fresh application:

You may choose to make purchases through your myNavigon account within the Navigon Fresh application. If you choose to do this, you will be asked for your name, billing address, shipping address, email address, residence, and payment method information.

Purposes and Legal Grounds:

(a) Garmin processes your name and shipping address to deliver the purchased product. The legal ground for processing your name and shipping address for this purpose is performance of a contract.

(b) Garmin processes your email address to send confirmation of the order and any notifications related to the order. The legal ground for processing your email address for this purpose is performance of a contract.

(c) Garmin processes your IP address, country, and residence for purposes of ensuring compliance with applicable laws and regulations. The legal ground for processing your IP address, country, and residence for this purpose is our legitimate interest in compliance with applicable laws and regulations.

(d) Garmin uses a third-party service provider, Ingenico ePayments, to process payments for customers who make purchases through their myNavigon account within the Navigon Fresh application. We recommend you carefully review Ingenico’s Privacy Policy.

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. With your consent, our customer support representatives may sign in to your myNavigon account, if appropriate, to help troubleshoot and resolve your issue.

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. The legal ground for signing in to your myNavigon account, if appropriate, to help troubleshoot and resolve your issue is consent, which you may withdraw.

Cookies and Similar Technologies

We collect data from users about their usage of the Navigon Fresh application. 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 the Navigon Fresh application; to develop and market products and features that best serve you and other users; and to help identify and fix application 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 products and applications so we can enhance the user experience and functionality of our products and applications.

Categories of Recipients of Personal Data

Ingenico ePayments:

Garmin uses a third party, Ingenico ePayments, to process payments for purchases made through the Navigon Fresh application and your myNavigon account. Garmin shares your name, billing address, payment method information, and transaction information for the purpose of processing payment for orders. The legal ground for processing your personal data for this purpose is performance of a contract. Garmin also shares transaction information, your name, billing and shipping addresses, payment method details, residence, country, and IP address with Ingenico for the purposes of fraud detection and prevention. The legal ground for processing your personal data for that purpose is our legitimate interest in protecting Garmin and our customers from attempts to engage in fraudulent transactions.

SharpMind:

Garmin uses a third-party service, SharpMind, to maintain the servers which provide services within the Navigon Fresh application. These servers send or retrieve data through the Navigon Fresh application for delivery to your Navigon product or account upon request. Other service providers: Garmin uses third-party content delivery networks (CDNs), such as Akamai and StackPath, to deliver mapping content to your Navigon product or myNavigon account upon request.

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.

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 associated with your myNavigon account as long as your myNavigon account is considered to be active. We will retain usage data 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].