Personal data that is processed when you create a Garmin account:

When you create a Garmin account, we ask you to provide your email address, name, and password. You can choose to provide only your first name or a nickname instead of your full name if you wish. We may also ask you to provide your mobile phone number.

PURPOSES AND LEGAL GROUNDS:

(a) We process your email address and password because you use your email address and password to sign in to your account. The legal ground for processing your email address and password for this purpose is our legitimate interest in protecting the security of your account. If you enable two-factor authentication, we process your mobile phone number or email address to send the security code via SMS or email. The legal ground for processing this information for this purpose is our legitimate interest in protecting the security of your account. If you reside in mainland China, we process your mobile phone number for purposes of real name authentication.

(b) We also process your email address for the purpose of sending you important information about your Garmin products, services, apps, or account, such as important safety information or material changes to this Privacy Policy. The name you provide is associated with your account profile and is displayed when you submit comments or other material on our websites or apps or engage with other users. The legal ground for processing your email address and name for these purposes is our legitimate interest in providing you important safety or other information about your Garmin products, services, apps, or account or material changes to this Privacy Policy and in providing you an opportunity to engage with other users.

(c) If you provide your opt-in consent to receiving marketing information from us, we will also process your email address for the purpose of sending you marketing information about our products, services, and apps, as well as newsletters. 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 Garmin account or through the unsubscribe link at the bottom of our marketing emails. The marketing emails you receive from us are based on the preferences you provide in your Garmin account, the locale indicated by your Internet Protocol (IP) address, the types of Garmin devices you have added to your Garmin account, and any subscriptions included in your Garmin account. The legal ground for processing this data for this purpose is our 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. If you reside in mainland China, we may use your mobile phone number to send you marketing communications via SMS.

(d) We also process your email address to associate it with your Garmin 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) We also process your email address to notify customers when they have violated our terms. The legal ground for this processing is our legitimate interest in ensuring a quality experience for all customers and ensuring adherence to our terms.

Personal data that is processed when you sign in to your Garmin account with social media credentials if you choose (mainland China only):

If you live in mainland China, you may choose to sign in to your Garmin account using your social media sign in credentials (e.g., your WeChat, QQ, or Apple sign-in credentials). If you choose this method, the first time you sign-in, you will be asked whether you agree to the social media provider delivering certain information to us, such as your identifier, nickname, email address, profile photo, and other information associated with your social media account.

All of this information is made available to us by the social media provider due to the way the social sign-on configuration works. However, the only information we retain and process is your email address. If you do not want your information to be shared with us by the social media provider, then you can simply sign-in to your Garmin account using your Garmin account credentials instead of your social media account credentials.

PURPOSE AND LEGAL GROUND:

We associate the email address provided by the social media provider with your Garmin account so that you can use your email address to sign in to your Garmin account in the future if you no longer wish to sign in using your social media account credentials. The legal ground for processing this information for this purpose is our legitimate interest in providing you an alternative sign-in method and in securing your account.

Additional personal data that is processed if you choose to provide it when you create a profile:

You can add additional information to your profile, such as your location, types of activities you participate in (e.g., running, hiking, cycling, golf, etc.), and a photo, and your gender, birthdate, height, and weight.

PURPOSES AND LEGAL GROUND:

This information is used to calculate the calories you burn during an activity and to enable you to show your Connections the types of activities you participate in if you wish. The legal ground for processing this information for these purposes is your consent. You can withdraw your consent by deleting this information from your account profile.

Personal data that is processed when you choose to upload or add your data to your Garmin account:

You can choose to upload from your device or, in some cases, manually add activities (e.g., runs, walks, bike rides, swims, hikes, gym activities, etc.) and activity data (e.g., steps, distance, pace, activity time, calories burned, heart rate, sleep, location, golf stats, menstrual cycle information, hydration, music played, etc.) to your Garmin account. You can use your device without providing your consent to upload your activities to your Garmin account. If you choose to add your activities to your Garmin account, you control whether others can see your activity data by managing the privacy settings in your Garmin account. Your activity data is set to "Private" by default.

PURPOSES AND LEGAL GROUNDS:

(a) We process this data, if you choose to upload or add it to your Garmin account, to enable you to analyze this data, identify any Garmin devices used to collect data during the activity, see your location on your activity course and segment maps, see your heart rate related metrics such as stress score, Body Battery, or pulse oximetry, track your fitness goals, and, if you wish, share this data with others. If you reside in the EEA, U.K., or Switzerland, the legal ground for this processing is your explicit consent, which you can withdraw at any time within your Garmin account.

(b) If you choose to upload or add this data to your Garmin account and you choose to participate in Insights, then you will be presented with an Insights section in your Garmin account in which you will be provided with recommendations and motivational messages, information, and links to articles that may be of interest to you based upon this data, and a comparison of this data with aggregated activity data of others in the Garmin Connect community. If you reside in the EEA, U.K., or Switzerland, the legal ground for processing this data for this purpose is your explicit consent, which you can withdraw at any time within your Garmin account.

(c) We also process this data, if you choose to upload or add it to your Garmin account, in an aggregated manner to analyze usage and trends and develop or improve features and services. The legal ground for this processing is our legitimate interest in providing relevant and quality features and services.

(d) If you choose to upload or add this data to your Garmin account and you are opted in to product improvement, we will process this data for research and development purposes internally to help us build better and more relevant Garmin products and services. If you reside in the EEA, U.K., or Switzerland, the legal ground for processing this data for this purpose is your explicit consent, which you can withdraw at any time within your Garmin account.

Personal data that is processed when you add a Garmin device to your Garmin account:

When you add certain Garmin devices to your Garmin account, we ask for additional information, such as your gender, height, weight, birthdate, activity level (low, medium, or high), and normal bed and wake times.

PURPOSES AND LEGAL GROUND:

This information is processed to calculate the calories you burn during an activity, provide you Insights about your activities and sleep (if you give your explicit consent to be presented with Insights), and to set your wearable device to “do not disturb” mode during your normal sleep hours. The legal ground for processing this information for these purposes is your consent. You can withdraw your consent at any time by removing your device from your Garmin account and deleting this information from your profile.

Personal data that is processed when you enable email notifications:

If you enable email notifications, we process your email address in accordance with your notification settings.

PURPOSE AND LEGAL GROUND:

If you provide your opt-in consent, we will process your email address for the purpose of sending you notifications based on your selections (e.g., when you join a Challenge, when a Challenge is over, when comments to a Challenge are submitted, etc.). The legal ground for processing your email address for this purpose is your consent. You can withdraw this consent at any time by changing your email settings to opt out of receiving such notifications or by disabling email notifications.

Personal data that is processed when you sync your Garmin device:

When you sync your device through the Garmin Connect website or mobile app or Garmin Express, we log data about the transmission, such as the IP address used when syncing, the sync time and date, crash/diagnostic logs, geographic location of the device, information about your device, information about the network used to sync (e.g., Wi-Fi or cellular), and device battery level. For compatible products, we will also gather analytics on how you configure and use certain features (e.g., Garmin Pay, Connect IQ, music features, etc.).

PURPOSES AND LEGAL GROUNDS:

We process this information to help identify and resolve errors or syncing issues. The legal ground for processing this information for this purpose is our legitimate interest in resolving errors or syncing issues and providing quality product support. We also process this information to analyze usage and trends and develop or improve features and services. The legal ground for this processing is our legitimate interest in providing relevant and quality features and services.

Personal data that is processed when you connect your Garmin account to a third-party app if you choose:

If you choose to enable your Garmin account to access accounts you have with other app providers, such as your MyFitnessPal, Strava, or TrainingPeaks account, we will obtain information about you from such account, such as the number of calories consumed in a particular day based on information from your MyFitnessPal account or courses and segments from your Strava account.

PURPOSE AND LEGAL GROUND:

This information is used to supplement your activity information in Garmin Connect with information you have provided to such third-party apps. The legal ground for this processing is your consent. You can withdraw your consent at any time by disconnecting your Garmin account from the third-party app within your Garmin account.

Personal data that is processed when you communicate with Garmin:

When you interact with our customer support representatives by email or 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, and subscriptions you've purchased. 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 Garmin account, if appropriate, to help troubleshoot and resolve your issue.

PURPOSES AND LEGAL GROUNDS:

We use this information to provide you with customer and product support, to monitor the quality and types of customer and product support we provide to our customers, and to facilitate repairs, returns, or exchanges. The legal ground for processing this information for these purposes is our legitimate interest in providing quality product support. The legal ground for signing in to your Garmin account, if appropriate, to help troubleshoot and resolve your issue is your consent, which you may withdraw.

Personal data that is processed when you use location-based services:

If you choose to use location-based services, such as weather, on your Garmin device or app, then the physical location of your device will be collected in order for Garmin or our providers to provide you with such location-based services.

PURPOSE AND LEGAL GROUND:

The purpose of processing the location of your device is to provide you the location-based services you wish to use. The legal ground for processing this data for this purpose is performance of a contract.

Personal data that is processed when you are a real-time tracking (e.g., LiveTrack) invitee or emergency contact on someone's Garmin account:

If a Garmin user sends you an invitation to track their location or activity in real time (e.g., via the LiveTrack feature) or adds you as an emergency contact to their Garmin account, they provide us your phone number or email address.

PURPOSE AND LEGAL GROUND:

We use this information to send you the real-time tracking information or to notify you of an incident involving the Garmin user. The legal ground for processing this information for these purposes is our legitimate interest in enabling our users to send real-time tracking information to their friends and family, and in enabling our users to notify their emergency contacts if they are involved in an incident and need assistance.

Personal data that is processed when you use the Assistance Plus service:

When you use the Assistance Plus service, we process your email address, mailing address, telephone number, and contact information for your chosen emergency contacts. We also process text messages sent to and from your device and the location of your device when your device communicates with the Garmin International Emergency Response Coordination Center (IERCC).

PURPOSES AND LEGAL GROUNDS:

(a) We process text messages sent to and from your device and the location of your device when your device communicates with the Garmin IERCC in order for Garmin and its service providers to perform the Assistance Plus service. The legal ground for this processing is performance of a contract.

(b) We process your mailing address and telephone number to determine if the Garmin IERCC has been activated inadvertently by a subscriber at their residence. The legal ground for this processing is our legitimate interest in minimizing the number of false alarms.

OTHER GARMIN CONNECT USERS:

Your activities and activity data associated with your Garmin account are set to "Private" by default. You may decide to allow others to view your activities and activity data by changing the privacy settings in your Garmin account. You can join Groups and make Connections with other Garmin Connect users. You may also choose to join other Garmin Connect users in Challenges and Leaderboards. When you interact with others in these ways, you will be displaying your data relating to the Challenge or Leaderboard (e.g., aggregate number of steps during the duration of a steps Leaderboard or Challenge) even if your privacy settings in your Garmin account are set to "Private."

FAMILY MEMBERS OF GARMIN JR. CHALLENGE PARTICIPANTS:

When you choose to participate in Challenges that include participants who are part of a Garmin Jr. family account, Challenge participants and anyone in their family account may view your data relating to the Challenge and its Leaderboard, even if they are not participating in the Challenge and even if your privacy settings in your Garmin account are set to "Private."

YOUR REAL-TIME TRACKING INVITEES:

Some Garmin devices include features, such as LiveTrack, that enable you to send a link to people of your choice that allows them to see the real-time location of your device. Because anyone with access to the link will be able to see the real-time location of your Garmin device, you should use caution in determining to whom you want to send the link and be sure that you trust them to not send the link to others whom you do not want to be able to view the location of your Garmin device.

YOUR EMERGENCY CONTACTS:

If you provide emergency contacts to us to be used in the event that an incident is detected or reported and you are involved in an incident that is detected by your Garmin device, we will send a notification with information about the incident, such as location, to your chosen emergency contacts via SMS or email.

GARMIN IERCC, SEARCH AND RESCUE AUTHORITIES, AND EMERGENCY RESPONDERS:

In connection with your use of the Assistance Plus service, Garmin, through the Garmin IERCC, may provide information, such as your name, email address, mailing address, telephone number, the message content, time sent, and the identity and location of the message sender and recipient, to competent search and rescue authorities and emergency responders.

THIRD-PARTY APP, PLATFORM, OR SERVICE PROVIDERS WITH WHOM YOU ASK GARMIN TO SHARE YOUR DATA:

If you choose to authorize us to permit a third party, such as your wellness program provider, or an app, such as MyFitnessPal, Strava, or TrainingPeaks, to access your activity data in your Garmin account, then we will share such data with the third party. We will not do this without your explicit consent. Once you direct us to share data with a third party, the third party's handling of your personal data is the responsibility of that third party, and you should carefully review the third party's privacy policy. You can choose to stop sharing data with the third-party app, platform, or service provider at any time within your Garmin account.

OTHER SERVICE PROVIDERS:

We use cloud services from third parties such as Adobe and SendGrid, a Twilio service, to assist in sending emails. Those services track the activities associated with these emails, such as whether they were opened, whether links in the emails were clicked on, and whether purchases were made following clicks on those links. We use this data to analyze the level of engagement with our emails.

We use services from third parties such as Vonage and Twilio to send SMS messages to our users or their contacts in support of features described in this Privacy Policy. We may track the delivery of these messages based on the phone number of the recipient and the selected content. We use other SMS vendors in some regions, such as Alibaba Cloud (mainland China only).

We use third-party service providers to help us better understand the usage and performance of our products, services, websites, and apps. See the "Monitoring and Analytics" section for more information.

OTHER DISCLOSURES:

We may process and disclose personal data about you to others: (a) if we have your valid consent to do so; (b) to comply with legal obligations, such as a valid subpoena, court or judicial order, or other valid legal process; (c) to enforce any of our terms and conditions or policies; (d) as necessary to pursue available legal remedies or defend legal claims; or (e) as we deem necessary or appropriate for purposes of attempting to get you help in the event you are involved in an emergency situation.

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 our 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 to 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.

Garmin is a global business. To offer our products, apps, and services, we may need to transfer your personal data to Garmin-owned companies in other countries. View Garmin-owned companies.

For customers outside of mainland China, when you create a Garmin account, add personal data in your account profile, or upload data to your Garmin account, your personal data will be collected and stored on servers in the U.S., U.K., and/or Australia. For customers in mainland China, when you create a Garmin account, add personal data in your account profile, or upload data to your Garmin account, your personal data will be collected and stored on Garmin China Shanghai RHQ Co., Ltd.’s servers in mainland China.

Personal data regarding individuals who reside in a country in the European Economic Area ("EEA"), United Kingdom ("U.K."), or Switzerland is controlled by Garmin Würzburg GmbH and processed on its behalf by other Garmin-owned companies to provide support, infrastructure, security, and other key functions. Garmin Würzburg GmbH has entered into approved model contractual clauses where these companies are not located in the EEA or a jurisdiction deemed adequate under applicable data protection law.

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

Information about Garmin's use of cookies and similar technologies on our websites can be found in our Cookie Policy.

We collect data from users about their usage of our products, services, websites, and apps. The types of analytical information that are collected include the date and time of access to our servers, software or firmware version, the location of the device, language setting, what information and files have been downloaded, 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 product, service, website, or app functions. Garmin uses this data to improve the quality, security, and functionality of our products, services, websites, or apps; to develop and market products and features that best serve you and other users; and to help identify and fix 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, services, websites, and apps so we can enhance user experience and functionality.

Here are examples of third-party providers we currently use:

• Google: Google Analytics is used to track statistics and user demographics, interests, and behavior. 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.

• Azure Application Insights: Azure Application Insights, a Microsoft service, is used to help us better understand usage to improve user experience.

• Microsoft App Center; Firebase (Crashlytics): Microsoft App Center, formerly known as HockeyApp, and Firebase (Crashlytics), a Google service, are used to help us better understand usage to improve user experience and to identify and resolve the root causes of crashes or errors.

See the "Cookies and Similar Technologies" section for information on Monitoring and Analytics vendors that rely on cookies.

We request individuals under the age of 13 in the U.S. and under the age of 16 in the rest of the world not provide personal data to Garmin. If we learn that we have collected personal data from a child under the age of 13 in the U.S. or under 16 in the rest of the world, we will take steps to delete the information as soon as possible.

We may update this Privacy Policy from time to time as we add new products, services, 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.

We will retain your personal data as long as your Garmin account is considered to be active or in accordance with applicable law and regulatory obligations. In addition, see below under “Your Rights” for a description of your right of erasure.

Garmin does not make any decisions based on algorithms or other automated processing that significantly affect you.

If you reside in a country in the EEA, U.K., or Switzerland, then your personal data collected by Garmin is controlled by Garmin Würzburg GmbH, Beethovenstr. 1a, 97080 Würzburg, Germany. The company's EU Data Protection Officer can be reached by email at [email protected].

If you reside in mainland China, then your personal data collected by Garmin is controlled by Garmin China Shanghai RHQ Co., Ltd., 37F, Tower A, New CHJ International Business Center, No 391, Guiping Road, Xuhui District, Shanghai 200233, China. The company's Data Protection Officer for mainland China can be reached at the same address and by email at [email protected].

If you reside outside of the EEA, U.K., Switzerland, and mainland China, then your personal data collected by Garmin is controlled by Garmin International, Inc., 1200 E. 151^st St., Olathe, Kansas 66062, USA, which you can contact by email at [email protected]. The company's Brazilian Data Protection Officer is located at the same address and can be reached by email at [email protected]. The company's Turkish Representative can be reached by email at [email protected].

If you reside in the EEA, U.K., or Switzerland, you have the right, subject to the conditions set out in the General Data Protection Regulation ("GDPR") or other applicable law, 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. 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. If you reside outside of the EEA, U.K., and Switzerland, you may have similar rights under your local laws.

To request access to or rectification, portability, or erasure of your personal data, or to delete your Garmin account, please visit our Account Management Center.

If you reside in the EEA, U.K., or Switzerland and you wish to exercise your right to restriction of processing or your right to object to processing, please contact the company's EU Data Protection Officer at Garmin Würzburg GmbH, Beethovenstr. 1a, 97080 Würzburg, Germany, or by email at [email protected].

If you reside in mainland China and you wish to exercise any of your data subject rights, please contact Garmin China Shanghai RHQ Co., Ltd. by email at [email protected].

If you do not reside in the EEA, U.K., Switzerland, or mainland China but you believe you have a right to exercise these or any other rights under your local laws, please contact Garmin International, Inc. by email at [email protected].

Notice for California Residents of Privacy Practices and Rights

If you are a California resident, California law may provide you with additional rights regarding your personal data. To learn more about your California privacy rights, please visit our CCPA Privacy Notice.

All trademarks are the property of their respective owners.

• April 29, 2021
• June 5, 2020