PRIVACY POLICY FOR GARMIN PAY

Last updated: Nov. 7, 2019

Your privacy is important to Garmin. We developed this Privacy Policy so you know how we process your personal data when you use our Garmin Pay service. In this Privacy Policy, references to “Garmin Pay wallet” are intended to apply to the wallet on your Garmin device or, if applicable, on your third-party device, which might use a name other than Garmin Pay.

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. For example, we have a separate privacy statement that applies to Garmin Connect and its compatible wearables and other devices.

“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 set up a Garmin Pay wallet:

When you set up a Garmin Pay wallet, we collect user information, such as first name and last name and an authentication token and, when Garmin Pay will be used on a third-party device, a username and email address. We also collect device information, such as serial number, model (device and phone), identifier, firmware version, and operating system.

PURPOSES AND LEGAL GROUNDS:

(a) Garmin processes your first name, last name, and authentication token to use for authentication purposes. The legal ground for processing your first name, last name, and authentication token for this purpose is based on Garmin’s legitimate interest in protecting the security of your Garmin Pay wallet.

(b) For third-party device users, Garmin processes your username and email address because you use this information to sign in to your Garmin Pay wallet. The legal ground for processing your username and email address for this purpose is Garmin’s legitimate interest in protecting the security of your Garmin Pay wallet.

(c) Garmin also processes your username and email address for use in fraud detection measures. The legal ground for processing your username and email address for this purpose is Garmin’s legitimate interest in detecting and preventing fraud and to comply with the requirements of issuing banks and payment networks.

(d) For customers using Garmin Pay on a Garmin device, Garmin also processes your email address for the purpose of sending you important information about your Garmin Pay wallet 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 information about your Garmin Pay wallet or material changes to this privacy policy.

Personal data that is processed when you add payment methods in your Garmin Pay wallet:

When you add a payment method to your Garmin Pay wallet, we collect your first name, last name, billing address, and payment information — such as the card number, expiration date, and CVV — and any other information that the issuing bank or payment network may require to verify your identity or device.

PURPOSE AND LEGAL GROUND:

(a) We process this information to validate your identity with the issuing bank or payment network as per their requirements. The legal ground for processing this information for this purpose is Garmin’s legitimate interest in protecting our customers from fraud.

(b) We also process this information so the issuing bank or payment network can validate the card and generate the payment token for use in the Garmin Pay wallet. Once this payment token is generated, we store it and other card information, such as the last four digits of the card number, the name on the card, credit card art, card type, and billing address. The legal ground for processing this information for this purpose is contractual necessity.

Personal data that is processed when you view, suspend, or delete payment methods in your Garmin Pay wallet:

When you choose to view a payment method in your Garmin Pay wallet, we will show you the stored card information, specifically the last four digits of the card number, the name on the card, credit card art, card type, and billing address. When you choose to suspend a payment method in your Garmin Pay wallet, we will retain the stored card information. However, we will notify the issuing bank or payment network to block it from making purchases. When you choose to remove a payment method from your Garmin Pay wallet, we will delete the stored card information as requested and notify the issuing bank or payment network to block it from making purchases.

PURPOSE AND LEGAL GROUND:

We process this information to fulfill your requested actions. The legal ground for processing this information for this purpose is contractual necessity.

Personal data that is processed when you make a purchase using your Garmin Pay wallet:

If you use your Garmin Pay wallet to make a purchase, your payment token is presented to the vendor’s point-of-sale system. After the transaction is completed, at the discretion of the issuing bank or payment network, Garmin may receive confirmation of the successful payment.

PURPOSE AND LEGAL GROUND:

The payment token is provided to the vendor, which will send the information to the issuing bank or payment network to process the payment. The issuing bank or payment network sends confirmation of the successful payment to Garmin so that the Garmin Pay service can send a push notification to you about the completed payment. The legal ground for processing this information for these purposes is contractual necessity.

Categories of Recipients of Personal Data

Issuing banks and payment networks:

To provide the service, Garmin will share information with issuing banks and payment networks as needed for purposes of fraud detection, obtaining a payment token representing your credit card, and displaying transaction information.

Service providers:

Garmin uses Amazon Web Services to host and provide the Garmin Pay service. Garmin also uses Zendesk to provide Tier 2 customer support for your device’s provider, issuing bank, or payment network as they assist you with issues related to Garmin Pay. Garmin uses third-party service providers to help us better understand how people are using the Garmin Pay service.

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 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.

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. 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 International Inc.’s servers in the U.S. Personal data regarding individuals who reside in a country in the European Economic Area ("EEA"), the United Kingdom ("U.K.") or Switzerland is controlled by Garmin Würzburg GmbH and processed on its behalf by Garmin International, Inc., Garmin Services, Inc., and Garmin AT, Inc.

Garmin International, Inc., Garmin Services, Inc., and Garmin AT, Inc. comply with the EU-U.S. and Swiss-U.S. Privacy Shield principles regarding the collection, use, sharing and retention of personal information from the EEA, U.K. and Switzerland, as described in our EU-U.S. Privacy Shield certification and Swiss-U.S. Privacy Shield certification. Learn more about Privacy Shield.

Garmin International, Inc., Garmin Services, Inc., and Garmin AT, Inc. are subject to the oversight of the U.S. Federal Trade Commission and remain responsible for personal data transferred to third parties that process it on our behalf. If you have a complaint about our Privacy Shield compliance, please contact us at [email protected]. You can also refer a complaint to our chosen independent dispute resolution body, JAMS, and in certain circumstances, invoke the Privacy Shield arbitration process.

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 the Garmin Pay service. We collect analytical information such as the date and time a user accesses the service, device information, language setting, 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 service functions. Garmin uses this data to improve the quality and functionality of the service, to develop and market products and features that best serve you and other users, and to help identify and fix service 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 the Garmin Pay service so we can enhance the user experience and functionality of the service.

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

ANALYTICS SERVICES:

  • Google: Google Analytics is used to track statistics and user demographics, interests, and behavior on the Garmin Pay service. 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.

Children

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.

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 as long as your Garmin account is considered active or, in the case of Garmin Pay users with third-party devices, until you or the data controller request deletion of your Garmin Pay wallet. In addition, see below under “Your Rights” for a description of your right of erasure.

Data Controller and Data Protection Officer

When Garmin acts as a processor:

When using Garmin Pay on a Swatch device, Garmin acts as a processor. To exercise your rights or for more information, please contact the third-party provider of your device.

When Garmin acts as a data controller:

When using Garmin Pay on a Garmin device or any other third-party device, Garmin acts as the data controller. If you reside in a country in the EEA, U.K. or Switzerland, personal data is controlled by Garmin Würzburg GmbH — located at Beethovenstraße 1a+b, 97080 Würzburg, Germany. The company's EU Data Protection Officer is located at the same address and can be reached by email at [email protected]

If you reside in China, personal data is controlled by Garmin China Shanghai RHQ Co. Ltd. — located at 37F, Tower A, New CHJ International Business Center, No 391, Guiping Road, Xuhui District, Shanghai 200233, China. You can contact them by email at [email protected]

If you reside outside of the EEA, U.K., Switzerland, and China, then the personal data is controlled by Garmin International, Inc., 1200 E. 151st St., Olathe, Kansas 66062, which you can contact by email at [email protected]

Your Rights

If you reside in the European Union or U.K., you have the right under the General Data Protection Regulation (GDPR) or U.K. Data Protection Act 2018 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 European Union and U.K., you may have similar rights under your local laws.

If you live in the European Union or U.K. and you wish to exercise any of your data subject rights related to the Garmin Pay service, please contact the company's EU Data Protection Officer at Garmin Würzburg GmbH at Beethovenstraße 1a+b, 97080 Würzburg, Germany, or by email at [email protected]

If you live in China and you wish to exercise any of your data subject rights related to the Garmin Pay service, please contact Garmin China Shanghai RHQ Co. Ltd. at [email protected]

If you do not live in the European Union, U.K., or China, but you believe you have a right to exercise these or other rights under your local laws related to the Garmin Pay service, please contact Garmin International, Inc. at [email protected]

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