Privacy Policy for Consumer Automotive Applications

Last updated: June 6, 2019

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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 mobile applications (“apps”) for Android or Apple systems related to our Consumer Automotive products and services, including Garmin HUD apps, Navigon apps, Navigon Select Telekom Edition apps, Garmin StreetPilot apps, the Garmin Sony Xperia Edition app, the Garmin Drive app, and the Garmin Smartphone Link 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, app store account information, 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, app store account information, and location for the purpose of authorizing and fulfilling requests for live location-based services. Within Android applications, Garmin also processes your Google Play account email address for the purpose of managing and providing subscription-based services across your Android devices. The legal ground for these processing activities 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 use the voice-based search feature in our Garmin Drive app or compatible products:

When you use voice-based search, we collect personal data, such as your device identifier, location, voice-based search requests, and the names of contacts and stored places of interest (POIs) to provide you with location-relevant search results.

Purpose and Legal Ground:

(a) Garmin processes your device identifier, location, and voice-based search requests for the purpose of completing the searches that you’ve requested. The legal ground for this processing is performance of a contract.

(b) Garmin processes your device identifier, names of contacts, and names of saved POIs for the purpose of providing enhanced search results that recognize names and words from your contacts and POIs. The legal ground for this processing is your consent. You can withdraw this consent at any time by disabling the feature under Settings.

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 or sell this data to 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 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 consent, which you may withdraw at any time within the settings of your Garmin device or app.

Categories of Recipients of Personal Data

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.

Voice recognition providers:

We may need to share your hashed identifier, contacts, saved POIs, location, and audio recordings to third-party service providers, such as Nuance, 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 (“EEA”), United Kingdom (“U.K.”), or in 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 here.

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 []( "Garmin Companies"). 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 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.

  • HockeyApp; Crashlytics (Fabric); Firebase: HockeyApp, a Microsoft service, and Crashlytics and Firebase, which are Google services, are used to help us better understand usage of Garmin 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 Connect website or through the vívofit jr. app

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 EEA, U.K., or 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 EEA, U.K., 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].

Your Rights

If you reside in the European Union or U.K., you have the right under the General Data Protection Regulation (“GDPR”) or UK 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.

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 or U.K. 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 1a+b, 97080 Würzburg, Germany, or by email at [email protected]. If you do not live in the European Union and U.K. 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].

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