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PRIVACY POLICY AND TERMS OF SITE AND TOOLBOX USE

SUMMARY OF THE PRIVACY POLICY AND TERMS OF SITE AND TOOLBOX USE

 

This document is a short summary of the Privacy Policy and Terms of Site and Toolbox Use (hereinafter referred to as the „Policy”). More detailed information on data processing is available in the full version of the Policy accessible below. Please note that only the full version of the Policy is considered as complete and adequate information. The purpose of this summary is only to give a better understanding of the Policy.

 

Purpose of data processing

Registration on the Site and for the Toolbox

Subscription to newsletters

Data controller

·         NNG

 

·         NNG

 

Scope of processed data

·         User’s title;

·         User’s name;

·         User’s email address;

·         User’s password in an encrypted form;

·         User’s address;

·         Country of permanent or temporary residence;

·         User Activity.

 

·         User’s name;

·         User’s email address.

 

Legal basis

·         User’s consent.

·         As of 25th May 2018, the performance of a contract to which the User is a party.

 

·         User’s consent.

Duration of data processing

·         The period during which the Update is available (expectedly 10 years), or until the User cancels his/her account.

 

·         The period during which the Update is available (expectedly 10 years), or until the User unsubscribes from the newsletter.

 

Data processor

 

·         Sales force

 

 PRIVACY POLICY AND TERMS OF SITE AND TOOLBOX USE

This Privacy Policy and Terms of Site and Toolbox Use (hereinafter referred to as the „Policy”) was posted on and is effective as of 25 May 2017.

Previous version


1. DEFINITIONS

Anonymous Data means information that is not associated with or linked to your personal data; therefore, the Anonymous Data cannot be used for identification purposes.
Connected Services mean location-based services (local search, traffic information, fuel price, weather information, etc.), which require some form of online connectivity (data access via an SIM card or Bluetooth, wireless internet access, TMC receiver, etc.) on your Device.
Content means maps, points of interest, 3D content, voices, language files, and other navigation-related content, which can be uploaded on your Device and used with your Software.
Cookie means a small text file, which is placed on your hard disk by a web server, and is used by the Site and the Toolbox as set forth in section Privacy below.
Device means a device with GPS capability, such as
• Personal navigation devices (also called PND or PNA);
• Smartphones/personal digital assistants (also called PDAs), including SD cards and other storage media (if the Software or the Content is stored on them);
• Mobile phones with GPS capability;
• In-car navigation systems;
• PCs, notebooks, and tablet PCs with GPS capability;
• Personal media players (PMPs) with GPS capability.
NNG means NNG Software Developing and Commercial Limited Liability Company, which provides the Software and the Product.
Registered office: H-1037 Budapest, Szépvölgyi út 35-37, Hungary
Court of registration: Budapest-Capital Regional Court (Fővárosi Törvényszék)
Company registration number: Cg.01-09-891838
Tax number: 13357845-2-44
Email address: unsubscribe@naviextras.com
Product means Updates, Contents, and Connected Services.
Site means naviextras.com and its subdomains.
Software means the navigation software that runs on your Device.
Toolbox means a free software tool for PC and OSX, which is used to download Updates and Products from NNG’s servers and upload them to the Device.
Updates mean Content and Software updates, which are provided by your Device manufacturer or Software developer, and which provide additional features, new Content versions, or fix known Software problems.
User means a registered visitor of the Site and/or the Toolbox.
User Activity means location and behaviour data (language selection on the Site or in the Toolbox, products put in the User’s cart), onsite browsing history, usage patterns (frequency/patterns of logging-in).

2. PRIVACY POLICY

2.1. Purpose of this document

This Policy sets the terms and conditions of how the data subject’s (hereinafter referred to as the “User” or “you”) personal or anonymous information is processed. Please read these terms and conditions carefully!

2.2. Availability and updating of this document

NNG reserves the right to amend this document unilaterally at any time. We suggest visiting the Site and the Toolbox from time to time for the latest information.

2.3. Data controller

2.3.1. The data provided on the Site and in the Toolbox is processed by NNG.

2.3.2. The provided data is accessible to the following persons:

• NNG’s employees involved in the data collection;
• IT specialists performing a variety of IT tasks related to the operation and maintenance of NNG’s computer system.

2.4. Data processing

2.4.1. Processing of data provided by the User during the registration on the Site and for the Toolbox

2.4.1.1. Purpose of data processing

a. Contacting the User in order to inform him/her about update services, Updates, and information on maps and services.

b. Provision of Updates

If the User wishes to download or purchase a Product, he/she shall register on the Site and download the Toolbox through the link available on the Site. By registering on the Site, the user also registers for the Toolbox. By registering on the Site and for the Toolbox, the User expressly and voluntarily gives his/her consent to NNG to process his/her personal data in compliance with the provisions of this Policy and the law on data protection.

2.4.1.2. Scope of the User’s processed personal data provided during the registration on the Site and for the Toolbox and the use of the Toolbox:

• User’s title;
• User’s name;
• User’s email address;
• User’s password in an encrypted form;
• User’s address;
• Country of permanent or temporary residence;
• User Activity.

2.4.1.3. Legal basis of data processing

a) The data is processed in compliance with Act CXII of 2011 on the right of informational self-determination and on freedom of information (“Privacy Act”). The legal basis of data processing is the User’s consent given pursuant to point a) of section 5(1) of the Privacy Act.

b) As of 25th May 2018, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”) shall apply. As of this date, the legal basis of data processing will be the performance of a contract to which the data subject is a party, as set forth in point b) of Article 6(1) of the GDPR.

2.4.1.4. Duration of data processing

Your personal data uploaded to the Site is retained for the period during which any Update or Product is available (expectedly 10 years), or until you cancel your account.

Notwithstanding the above, NNG shall immediately delete your personal data if you specifically request the deletion thereof.

2.4.2. Processing of data provided by the User for receiving newsletters

2.4.2.1. Purpose of data processing
NNG sends newsletters to inform the User about new Products and promotions, or other marketing activities.

2.4.2.2. Scope of the processed personal data of the User

• User’s name;
• User’s email address.

2.4.2.3. Legal basis of data processing

a) The data is processed in compliance with Act CXII of 2011 on the right of informational self-determination and on freedom of information (“Privacy Act”) and Act XLVIII of 2008 on the basic requirements and certain restrictions of commercial advertising activities (“Advertising Act”).

The legal basis of data processing is

• the User’s consent given pursuant to point a) of section 5(1) of the Privacy Act and
• the User’s consent given pursuant to sections 6(1) and (2) of the Advertising Act.

b) As of 25th May 2018, the GDPR shall apply. As of this date, the legal basis of data processing will be the consent of the data subject, as set forth in point a) in Article 6(1) of the GDPR.

2.4.2.4. Duration of data processing and subscription to the newsletter

2.4.2.4.1. Your personal data uploaded to the Site or the Toolbox is retained for the period during which the Update to your device is available (expectedly 10 years), or until you unsubscribe from the newsletter.

2.4.2.4.2. The User can subscribe to NNG’s newsletter on the Site or in the Toolbox. By ticking the appropriate checkbox, the User voluntarily gives his/her consent that NNG sends him/her a newsletter from time to time. NNG may send personalized newsletters to the User based on the data processed in compliance with this Policy.

2.4.2.4.3. The User may withdraw his/her consent at any time by sending an email to NNG from the email account in which he/she does not wish to receive newsletters in the future, or by sending mail to NNG’s postal address specified in section 1. The User may also unsubscribe (opt-out) at any time by following the instructions in the newsletter.

2.4.2.4.4. Please note that NNG may at any time decide to stop sending newsletters without prior notice, or further liability or obligation of any kind.

2.4.2.4.5. Registration number of such data controlling: NAIH-118611/2017.


2.5. Data processor

2.5.1. Data processing related to the sending of newsletters

2.5.1.1. For sending newsletters to the Users, NNG cooperates with a data processor, which provides email marketing services. The data processor provides NNG with an online system (hereinafter referred to as the “System”), through which NNG can manage the sending of newsletter to the Users. The data processor does not have access to the content uploaded by NNG to the System.

2.5.1.2. To improve user experience, the System is used for the following purposes:

• Storing the User’s personal data;
• Sending emails to the User;
• Analysing the User’s interaction with the delivered email (in particular whether the email was opened, how many times the addressee clicked on it, whether the addressee read the entire email);
• Analysing the bounce rate (e.g. cases in which the email address is invalid or the email is listed as spam).

2.5.1.3. The User data listed in section 2.4.2.2 is stored both in the System and on NNG’s servers.

2.5.1.4. NNG reserves the right to change the data processor at any time.

Name of NNG’s data processor: salesforce.com EMEA Limited
Address of the data processor: Floor 26 Salesforce Tower, 110 Bishopsgate EC2N 4AY London, UK


2.6. Cookies

2.6.1. NNG hereby informs you that if you download certain parts of the Site or the Toolbox, small data files (“Cookies”) will be automatically sent by the web server to your Device. In certain cases, these data files may be considered as personal data under the Hungarian law on privacy. These data files are necessary for the proper operation of the Site and the Toolbox, and are used to collect anonymous information on the User’s visits to the Site or in the Toolbox.

2.6.2. The User can accept or refuse Cookies on a case-by-case basis, or refuse all cookies by adjusting his/her browser settings. To find out how to do this and learn more on Cookies, please visit: https://www.youronlinechoices.eu/. If the User chooses to refuse all Cookies, access to some of the Site pages or Toolbox features will be limited.

 

Type of Cookie

Purpose of Cookies

Legal basis of data processing

Cookie retention period

Google Analytics

 

 

The Site and the Toolbox use the Google Analytics tool to collect and analyse information on how the User uses the Site and the Toolbox. We use the information to compile reports and improve the Site and the Toolbox. The data is collected in an anonymous form, including the number of Users to the Site and the Toolbox, where Users have come to the Site or the Toolbox from, and the pages they visited within the Site or the Toolbox. The collected data cannot be tracked back to the User. For further information on Google’s privacy policy, click here.

 

User’s consent.

Google Analytics Cookies are created as soon as the User visits a website on which a valid Google Analytics tracking code is installed. The Cookies will be held in the User's browser for a maximum period of 2 years from the above date.  For further information, please click here.

Google AdWords

(Google Remarketing)

Third-party service providers, including Google, store previous visits made by a User to the Site and the Toolbox, and use this information to display NNG’s advertisements to the User on the websites of Google’s partners.

When the User visits the Site or the Toolbox, we send one or more Cookies provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to your computer, which uniquely identify your browser. Google’s remarketing Cookies are used in Google AdWords. The Cookies provided by Google remember the number and times of visits to the Site or the Toolbox, as well as the sub-pages viewed by the User when browsing the Site or the Toolbox. The recorded data is stored anonymously.

The User can block Google’s remarketing Cookies on the opt-out page of Google’s Ads Settings, and can also block third-party Cookies on the Network Advertising Initiative opt-out page.

 

User’s consent.

The AdWords Cookies expire 90 days after the User visited the Site or the Toolbox.

For further information, please click here.

Session ID

Session Cookies allow the User to be recognized within the Site or the Toolbox.

The most common example of this functionality is the shopping cart feature of the Toolbox. When the User visits a page of a catalogue and selects some items, the session Cookie remembers the selection, so the shopping cart will contain the selected items when the User is ready to check out.

 

User’s consent.

The information is saved until the end of the current session. After that, the collected information will no longer be available.

 

Device

These Cookies remember the User’s Device choice, so that the Toolbox can navigate to that particular device when the User logs into the Toolbox next time.

 

User’s consent.

The Cookies will be held in the User's browser for a maximum period of 3 years.

Auto login

These Cookies remember the User’s login information and automatically fill out the login form for the User when the User starts the login process next time.

 

User’s consent.

The Cookies will be held in the User's browser for a maximum period of 6 months.

 
2.7. Data security

2.7.1. NNG observes all applicable regulations regarding the security of personal data, therefore both NNG and its authorized data processor implement appropriate technical and organizational measures to protect personal data, and establish adequate procedural rules to enforce the provisions of the Privacy Act concerning confidentiality and the security of data processing.

2.7.2. The data processor is compliant with the requirements of an information security management system (ISMS) specified by the ISO 27001 international standard, and is audited for compliance with ISO 27018. The data processor has achieved ISO 27001/27018 certification for its ISMS from an independent third party.

2.8. Rights and enforcement

2.8.1. Any personal information which you provide for NNG must be true, complete, and accurate in all respects. You agree to notify us of any change in your personal information via NNG’s email address specified in section 1 without delay.

2.8.2. The User may request the following from NNG as data controller:
• Information on the processing of his/her personal data;
• Rectification of his/her personal data; and
• Deletion or blocking his/her personal data (unless the processing of the personal data is mandatory).

2.8.3. You are entitled to request information on the data processing carried out by NNG, especially information as to what personal data relating to you is stored; the sources from which they were obtained; the purpose, grounds, and duration of processing; if your personal data is made available to others, the legal basis and the recipients; and any data protection incident in relation to your personal data by sending an email or mail to the email or postal address specified in section 1. NNG shall provide written information on the processing of your personal data within 25 days after receipt of the request. You may also request the correction or blocking of your personal data.

2.8.4. If your personal data is inaccurate, you may request NNG to rectify such data, provided that the correct data is at NNG’s disposal.

2.8.5. Your data shall be deleted upon your request. Your request for data deletion may be submitted to NNG by using the email or postal address specified in section 1. NNG shall delete all stored personal data in compliance with this Policy.

2.8.6. The personal data shall be blocked instead of being deleted if so requested by the User as a data subject, or if there are reasonable grounds to believe that the deletion could affect the legitimate interest of the User.

2.8.7. Please be informed that your data will not be deleted if the processing thereof is required by law.

2.8.8. You may lodge a complaint about the processing of your personal data to the National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság – NAIH; address: H-1125 Budapest, Szilágyi Erzsébet fasor 22/C.; postal address: 1530 Budapest, Pf. 5; 5 phone: +36-1-391-1400; facsimile: +36-1-391-1410; email: ugyfelszolgalat@naih.hu).

2.8.9. Independently from lodging a complaint to NAIH, you may turn to court pursuant to the provisions set forth in the Privacy Act if your rights are infringed. Upon your decision, the procedure may be launched before the tribunal in whose jurisdiction you are domiciled or you have a temporary address. Prior to initiating a legal procedure, it may be useful to discuss the complaint with NNG.

2.8.10. Your detailed rights and remedies are set out in subsections 14–18 and 21–23 of the Privacy Act.

2.9. Contacting NNG

We value your opinion. If you have any comments, questions, or wish to obtain more information on data processing at NNG, please send an email or mail to the email or postal address specified in section 1. We will handle the submitted information confidentially. Our representative will contact you within a reasonable time.

3. USE OF THE SITE AND THE TOOLBOX

3.1. Purpose of this document

3.1.1. This document lays down the terms of use of the Site and the Toolbox. Please read these terms and conditions carefully!

3.1.2. By using the Site and the Toolbox in any manner, you accept all the terms and conditions herein. You also agree that we may amend and/or revise this document at our discretion, and you agree to be bound by these revisions and amendments. We suggest visiting the Site and the Toolbox frequently for the latest information.

3.1.3. If you do not agree with these terms and conditions, we request that you immediately cease using the Site and the Toolbox.


3.2. Operation of the Site and the Toolbox

The Site and the Toolbox are operated by NNG.

3.3. Services provided by the Site and the Toolbox

• Detailed description of Updates, navigation Content for Users via e-delivery (downloading from the internet);
• Possibility to purchase or download Products on your Device;
• Possibility to subscribe to newsletters;
• Supporting troubleshooting by providing a section on frequently asked questions and customer care contact details.

3.4. Registration in the Toolbox

3.4.1. User registration

Some features of the Toolbox are available to registered Users only. Buying Updates, Contents, or Services requires User registration. The registration is easy and free. The User’s personal data shall be processed in compliance with the provisions of this Policy.
Please do not to share your username and/or password with any third party, or otherwise give any third party access to the Toolbox with your login data. You assume all liability for any unauthorized use of any username or password assigned to you.
You can delete your profile (with all your personal data) in the Toolbox at any time.

3.5. Content available on the Site and in the Toolbox

3.5.1. The texts, illustrations, and pictures displayed on the Site and in the Toolbox are for information purposes only, and shall not be considered as an offer. NNG does not make any representation regarding the correctness, accuracy, timeliness, or completeness of the content available on the Site and in the Toolbox. NNG reserves the right to change such information at any time, without prior notice. The information published on the Site and in the Toolbox may refer to products, programs, or services that are not available in your country. Such reference does not imply that NNG intends to sell such products, programs, or services in your country.

3.5.2. NNG shall not be liable for any direct or consequential damage, loss of profit, or additional costs, or damage of any kind resulting from the use of the Site or the Toolbox, or of false, incorrect, or incomplete content.

3.6. The User’s obligations

3.6.1. You agree not to interfere with, disrupt, or attempt to interfere with or disrupt the operation of the Site and the Toolbox or of the networks connected to the Site and the Toolbox, and you agree to abide to all security policies.

3.6.2. The User may not upload or otherwise publish any content on the Site or in the Toolbox, which is illegal in any way (copyrighted or illegal due to moral or other reasons).

 

3.7. Limiting User access

NNG may at any time limit your access to the Site or the Toolbox or some parts of the Site or the Toolbox at its sole discretion, as appropriate or necessary for security or business reasons, as a result of any alleged or suspected breach of these terms, or to protect intellectual property. The Site and the Toolbox may also impose limits on certain features or restrict your access to parts or all of the Site and the Toolbox without prior notice or any liability therefor. NNG may delete any User account and/or suspend User login without prior notice.

3.8. Availability of the Site and the Toolbox

We do not guarantee 24/7 reliable operation, availability, or uptime of the Site and the Toolbox, but we do make all reasonable efforts to ensure high availability.