Last Updated: April 29, 2021
“Personal data” is information relating to an identified or identifiable natural person.
- Categories of Personal Data Processed by Garmin
- Categories of Recipients of Personal Data
- Transfers of Personal Data
- Cookies and Similar Technologies
- Application Analytics
- Retention of Personal Data
- Automated Decision-Making, Including Profiling
- Data Controller and Data Protection Officer
- Your Rights
Categories of Personal Data Processed by Garmin
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.
PURPOSES AND LEGAL GROUNDS:
(a) Garmin processes 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 Garmin’s legitimate interest in protecting the security of your account.
(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, 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 Garmin 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 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 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) Garmin also processes 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 sync your Garmin device:
When you sync your Garmin device through 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.
PURPOSE AND LEGAL GROUND:
We process this information to help identify and resolve errors or syncing issues. The legal ground for processing this information for this purpose is Garmin’s legitimate interest in resolving errors or syncing issues and providing quality product support.
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 Garmin’s 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 your Garmin auto navigation device or app:
If you use a Garmin auto navigation device or app and provide your consent, then Garmin will collect and upload from your device data such as location, speed, direction, and time and date of recording. If you provide your consent when asked, then Garmin may also share this aggregated data with third parties to enhance the quality of the traffic, parking, and other features enabled by content providers.
PURPOSE AND LEGAL GROUND:
This data is aggregated with data from other consenting users and is used to enhance the quality of our products, services, and apps and the traffic, parking, and other features enabled by Garmin or third parties. The legal ground for processing this data for this purpose is your consent, which you may withdraw at any time within the settings of your Garmin device or app.
Personal data that is processed when you purchase a product, service, or subscription on a Garmin website or app or through customer support:
If you purchase a product, service, or subscription on a Garmin website or app or through customer support, then Garmin will collect your name, address, email address, and telephone number. We do not view or store your payment card information. Third-party payment processors are used depending on region and product purchased. These payment processors include Adyen, PayPal, Alipay (China only), WeChat Pay powered by tenpay (China only), UnionPay (China only), NewebPay, Klarna, and Veritrans. More information about Adyen can be found here. We also use Cybersource, a solution provided by Visa, in our fraud detection processes, and we use address verification services provided by third parties such as Google or CDYNE.
In some regions, another third party, Narvar, provides shipment information to allow you to track items purchased from a Garmin website or purchased, repaired, or exchanged through customer support.
PURPOSES AND LEGAL GROUNDS:
We collect your name, mailing address, and telephone number so we can process your order and fulfill your purchase. The legal ground for processing your name, mailing address, and telephone number for these purposes is performance of a contract. We also process your personal data as part of our fraud detection processes. 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.
Personal data that is processed when you purchase a product in a Garmin store:
When you purchase a product in a Garmin store, we may collect your name, address, telephone number, other contact information, or purchase details, such as invoice number or products purchased. In some countries, third-party providers may be used to generate the reporting required for the appropriate tax regulatory agency.
PURPOSES AND LEGAL GROUNDS:
We process this information to generate an invoice in our systems for tax reporting purposes or upon your request. The legal ground for processing your information for generation of an invoice for tax reporting purposes is fulfillment of a legal obligation. The legal ground for processing your information for generation of an invoice at your request is performance of a contract.
Personal data that is processed when you use location-based services on your Garmin device or app:
If you choose to use location-based services, such as weather, traffic information, fuel prices, movie times, and local event information, on your Garmin app or device, 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.
Categories of Recipients of Personal Data
YOUR LIVETRACK INVITEES:
LiveTrack is a feature available on some Garmin devices that enables 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.
OTHER SERVICE PROVIDERS:
Garmin uses 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. Garmin uses this data to analyze the level of engagement with its emails. Garmin also uses third-party service providers to help us better understand usage of Garmin Express and Garmin websites and apps and for related purposes.
Garmin uses third-party service providers to ship purchased products to customers. In some regions, Garmin uses a third party, Erply, to provide point-of-sale services for in-store purchases and another third party, Global Blue, to provide tax rebate paperwork for customers upon request. Garmin also uses a third-party service provider, VHT, to provide callback request functionality for customer support purposes.
We may 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; or (d) as necessary to pursue available legal remedies or defend legal claims.
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 Garmin-owned companies in other countries. View Garmin-owned companies.
For customers outside of 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 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 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 European Commission-approved model contractual clauses where these companies are not located in the EEA or a jurisdiction deemed adequate by the European Commission.
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.
We collect data from users about their usage of Garmin mobile apps and Garmin Express. 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 these and other 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 products and apps so we can enhance the user experience and functionality of our products and apps.
Here are examples of third-party providers we currently use:
Google: Google Analytics is used to track statistics and user demographics, interests, and behavior in apps. 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.
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 of our apps to improve user experience and to identify and resolve the root causes of app crashes.
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.
Retention of Personal Data
We will retain your personal data as long as your Garmin account is considered to be active. In addition, see below under “Your Rights” for a description of your right of erasure.
Automated Decision-Making, Including Profiling
Garmin does not make any decisions based on algorithms or other automated processing that significantly affect you.
Data Controller and Data Protection Officer
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 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, which you can contact by email at [email protected].
If you reside outside of the EEA, U.K., Switzerland, and China, then your personal data collected by Garmin is controlled by Garmin International, Inc., 1200 E. 151st 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].
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 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 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.
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