Last updated: 20 May 2019
Navmii Publishing Ltd respects your privacy. Navmii Publishing Ltd and its affiliates(“Navmii” or the “Company”) offer mapping, GPS navigation, community based services and Dashcam services to users of Navmii’s mobile applications (the“Application”) (collectively referred to as the “Services”). When you use our services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control.
Definitions and Interpretation
The following words and expressions have the following meanings unless inconsistent with the context:
“we”, “us” or “our”
“process” or “processing”
“sensitive personal data”
Satellite Navigation application as provided by us entitled Navmii, Navfree, Navmii AI Dashcam and CoCar
Matthew Thornhill who can be contacted by email at email@example.com or by post at Navmii, 41 Corsham Street, London N1 6DR;
Data Protection Act 1998 as amended from time to time;
as defined in the DPA;
Navmii Publishing Ltd a company registered inEngland and Wales with company number 06390277 whose registered office is at 41Corsham Street, London N1 6DR and who may be contacted on firstname.lastname@example.org
an individual, company, or firm accessing our App.
References to any statute or statutory provision include, unless the context otherwise requires, a reference to the statute or statutory provision as modified or re-enacted and in force from time to time, and any subordinate legislation made from time to time under the relevant statute or statutory provision.
References to persons include natural persons, firms, partnerships, companies, corporations, associations and organisations, (in each case whether or not having separate legal personality).
Use of any gender includes the other genders.
Words in the singular include the plural and words in the plural include the singular.
Any reference to “writing” or any cognate expression includes communications by post, email and facsimile but excludes text messages.
The headings to Conditions do not affect the interpretation of these Conditions.
Any phrase introduced by the term “include”, “including”, “in particular” or any similar expression will be construed as illustrative and will not limit the sense of the words preceding that term.
Our primary reason for collecting your personal data is to provide you with service updates and the most efficient service possible. We do not anticipate collecting or processing sensitive personal data about you.
Our App may contain links to websites. Please note that we are not responsible for the privacy practices of such other websites and advise you to read the privacy statements of each website you visit which collects personal information.
To use our Services you must be 16 years of age or older. If you are under 16, you may not download or use the Services.
Contact Navmii - Privacy concerns
If you have any queries about our processing or use of your personal data you should write, in the first instance to our Compliance Officer – email@example.com. If you want to learn more about your rights regarding your personal data, you should contact the Information Commissioner’s office information line on:(0044) 01625 545745 or visit their website at www.ico.gov.uk.
User Accounts & Accessing the Services
Please note that when you install the Application on your mobile device, Navmii will set up an account associated with that mobile device (the “Account” or “Navmii Account”). After installation, Navmii will collect and use your information, including meta-data (as described below), in accordance with this PrivacyPolicy. This use may include linking your information with your Account. This is the case irrespective of whether or not you choose to create a Navmii username and password in the Navmii Application (as explained below).
Navmii may allow you to use the Navmii Application whether or not you choose to set up a username for yourself. If you choose to use the Navmii Services without setting up a username you may do so by skipping the username setup stage of the application installation process. If you do so:
With the exception described in the bullet below, and as explained in the section “Visibility” below, your Account and the information associated with your Account (including your unique identifier) will be visible only to Navmii; and
When using the Application, your approximate location and other information you may choose to contribute will be visible to other users associated with a general non identifying username
If you do set up a Navmii username and password in the Application:
Navmii will link all of your information with your Account and that username. This includes information received from all mobile devices running the Application on which you have chosen to sign in using your username and password;
With the exception described in the bullet below and as explained in the section “Visibility” below, your Account and information associated with your Account will be visible only to Navmii; and
When using the Application, your approximate location and other information you may choose to contribute will be visible to other users associated with that username.
Navmii may also establish and require from time to time additional or different means of identification and authentication for logging in and accessing the Services or for accessing certain features or designated sections of the Services.
Your login details are your responsibility. You are fully accountable for any use or misuse of your Account and personal details as a result of conveying your login details to someone else. You must maintain your login details in absolute confidentiality and avoid disclosing them to others. Make sure that you change your password frequently and at least once every six months.
Information that is being collected
We want you to understand the types of information we collect as you use our services
Navmii collects information to provide better services to all its users - from figuring out stuff like what’s the best route, to more complex things like monitoring traffic so you know when to leave, and showing you relevant ads while using Navmii. The information Navmii collects, and how that information is used, depends on how you choose to use our services and how you manage your privacy controls.
Information you create or provide to us:
Account Information: information required when setting up a username you have chosen, such as your name and gender. Bear in mind that false, incorrect, or out-dated information may impair Navmii’s ability to provide you with the Services and to contact you when necessary. Navmii will explicitly indicate the fields for mandatory completion. If you do not enter the requisite data in these fields, you may not be able to set up a username (but you may still use our Services as explained in the above section “User Accounts & Accessing the Services”); and/or
Information that you choose to share with Navmii: information that you choose to share with Navmii, including a username you have chosen, reports associated with your username, phone number, “home” or “work”, other “favorites”, destinations you may travel to and search queries. Even if you aren’t signed in to a Navmii Account, you might choose to provide us with information - like an email address to receive updates about our services.
Communication which you choose to conduct through the Navmii Services: if you choose to use Navmii to communicate with other Navmii users or third parties through the Navmii Services, such as sending pinned locations on the Navmii platform. We may also collect information when you exchange communication with Navmii, for example, if you submit a request, contact Navmii’s support team via email, or report a violation to the abuse team.
Information from your social networks which you choose to connect to your Navmii Account: you may choose to connect your Navmii Account to your social network account(s). If you choose to do so, you may choose to share with Navmii and/or other users information from your social network accounts, such as your Facebook profile photo or other personal information shared by you. For more information see Integration with social networks, below.
Personal information may also be obtained automatically by your mobile device
If you place an order for goods and/or services and when you subsequently submit payment for that order we will collect personal data from you.
You may also provide additional information that will be used to personalise the Services and enhance your experience with the Services. For example, if you provide us with your “home” and “work”information, we may provide you with what we think is the preferred route between those locations.
Information we collect as you use our services
We collect information about your activity in the Services, which we use to provide you with the Services of Navmii, including features which are meant to personalize your experience. We may collect the information described in this section even if you are not logged into the app. The activity information we collect may include:
Detailed location, travel and route information. Location and route information is collected for example in the form of GPS signals (combined with a time-stamp) and other information sent by your mobile device on which the Application is installed and activated. This location and route information is saved to a route history of all of the journeys you have made while using the Application. The types of location data we collect depends in part on your device and account settings. For example, depending on your selected device settings and/or your account settings we may collect information about your location and travel (or lack thereof) also while you are not using the app, in order to be able to tell you when to leave for planned drives, notify you about bad traffic in your area, provide you parking assistance, analyse how effective our ads are and more;
Terms or venues you searched;
Your views and interactions with content and ads;
Communication or other content you chose to share with any third party, including Navmii users through the Services;
Your activity on third-party sites and apps that you chose to link to your Navmii account or that you interact with through the Service.
Meta-data(information about your device, browser and app use):
Once you install the Application, Navmii collects information about the use of theServices and information from the device you have Navmii installed on. For example:
Navmii may collect and record how often you use the app and for how long, your device type, unique identifiers, operating system type & version, battery usage, the third party web pages or applications you visit or use or interact with via the Application, information that you viewed on our Services, advertisements that are shown to you or that you view or click on, the fact that you used the Services to communicate with other users and the fact that you used third parties application/services via Navmii to communicate with third parties, and the duration of such communications, the Internet Protocol (IP) address and the name of the domain that serves you to access the Services, and the geographic location of the device that you are using to log in and use Navmii on.
We also collect information about the interaction of your devices with our Services, including, crash reports, system activity, and the date, time, and referrer URL of your request.
You should be able to adjust the settings on your mobile device to prevent our collection of location information by disabling Wi-Fi or Bluetooth functionality or disabling the location services feature on your device.
Information we collect about you from our partners
We work with ad partners, including entities that belong to the Google group of companies, in order to show you more relevant and useful ads based on your Navmii activity and information associated with your device’s identifier (i.e, Advertising identifiers or similar technologies) shared with us by our ad partners. Your device’s identifier can be managed in your device’s settings.
We may also receive aggregated, non-personally identifiable information and analysis from third parties measurement services which help us understand how our users interact with our ads. We may also receive information from third party services about how Navmii’s own marketing efforts performed on third party sites or platforms.
We use various technologies to collect and store information, including, cookies,Advertising ID available on Android mobile devices or similar technologies, local storage, browser web storage, application data caches, databases, and server logs.
Why Navmii collects data
Navmii may use information collected from or provided by you for the following purposes:
Provide our services
Weuse your information to deliver our services. For example:
Use your location and route information and/or search query history to provide navigation services, best route choices, traffic alerts and to provide information about sites, shops and other places and attractions in your close vicinity; and
To share your submissions with other users of the Services and to facilitate communication between you, Navmii and other users.
Maintain & improve our services
We also use your information to ensure our services are working as intended, such as tracking outages or troubleshooting issues you report to us. And we use your information to improve the service or to develop new features or services. For example, Navmii may use your route information to improve the accuracy of its mapping and navigation data.
We use data for analytics and measurement to understand how our services are used. For example, we analyse data about your usage of the Services to do things like optimise product design. We also use the data we collected about the ads you view or interact with (e.g. click on) to help advertisers understand the performance of their ad campaigns and to provide them with aggregated reports. We may also use data to measure the usability and effectiveness of Navmii’s own marketing efforts on third party sites or platforms.
Communicate with you
We also use your information to send you updates, notices, announcements, and additional information related to the Services;
We may also use your information to conduct surveys and questionnaires; And if you contact Navmii we may keep a record of your request in order to help solve any issues you might be facing.
Subject to your prior indication of consent (to the extent required under applicable law), we may also use the email address that you provided to send you promotional and/or marketing materials. At any time you may choose not to receive such materials by clicking on the “Unsubscribe” link in the email messages that we may send to you. In any case, Navmii will not share your contact details with any advertiser, unless explicitly permitted or required by law.
To protect Navmii, our users, the public and for Legal reasons
We may also use and process your information and content, using different technologies to the following purposes:
To contact you when Navmii believes it to be necessary;
To comply with any applicable law and assist law enforcement agencies under any applicable law, when Navmii has a good faith belief that Navmii’s cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures;
To detect abuse and illegal activity; to detect and prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services;
To handle breakdowns and malfunctions;
To take any action in any case of dispute, or legal proceeding of any kind between you and the Services, or between you and other users or third parties with respect to, or in relation with the Services;
To help improve the safety and reliability of our Services. This includes detecting, preventing, and responding to security risks, and technical issues that could harm Navmii, our users, or the public;
To create aggregated and/or anonymous data (where such data does not enable the identification of a specific user). See “How does Navmii use aggregated information”, below;
Sharing your information
Personal information that you share The Services are based on a community of users publicly sharing information with Navmii and with other members of that community.
In particular, users may choose to share personal information such as name, location information, reports and other files. This information may be shared directly to the Services and to all users, such as in the case of traffic reports on Navmii. This information may also be shared via third party services(such as social networks) which interact with the Services upon such users’ choice.
You can decide whether or not to upload content to the Services. However any content that you choose to share and submit for posting is neither private nor confidential and you should expect that it may be made public and known to others. Information you choose to upload will be posted along with your user name and other information including personal information you attached to your publicly available user profile. You should note that certain road incidents you report may include your driving path within the vicinity of those incidents. Therefore, you must exercise caution and common sense when submitting information. At the very least you should demonstrate the same degree of caution as when publishing personal information by means other than the Internet and cellular services.
In any event (but except as detailed below with respect to information shared from your social network accounts according to your privacy settings for such social network accounts), your email address will not be visible to others through any reports or user posts that you share or upload.
We, at Navmii, take great measures to provide you with the best experience you can have while using the Services. However, Navmii has no control over the conduct of any user and disclaims all liability in this regard. Users are advised to carefully and thoroughly consider whether or not to make public or available any information and carefully examine all necessary details related to any communication with other users prior to any engagement or communication being made.
Participating in any user’s activities as a result, directly or indirectly, from using Navmii, is entirely at your own risk. Navmii is not a party to any agreement entered into between the users in any circumstances. The user has the sole and ultimate responsibility regarding compliance with all laws, regulations or any other duty. We do not accept any liability for any loss, damage, cost or expense that you may suffer or incur as a result of or in connection with your participation in any activity or event initiated, held or conducted by a user or a third party nor in connection to any agreement between the users or third parties, including any activity or event related in any way, directly or indirectly, theServices or the use thereof.
When Navmii shares your information
Navmii does not sell, rent or lease your personal information to third parties. Navmii will not share your personal information with others, without your permission, except for the following purposes and to the extent necessary in Navmii’s good-faith discretion:
As necessary for the facilitation and operation of the Services. For example, making public road incidents you report and which are associated with your username and your location;
If Navmii is required, or reasonably believes that it is required by law to share or disclose your information;
In any case of dispute, or legal proceeding of any kind between you and Navmii, or between you and other users with respect to, or in relation with the Services;
In any case where Navmii reasonably believes that sharing information is necessary to protect against harm to the rights, property or safety of Navmii, our users, or the public as required or permitted by law, including to prevent imminent physical damage or damage to property;
To detect, prevent, or otherwise address fraud, security, or technical issues;
To collect, store, hold and manage your personal information through cloud based or hosting services or a third party or a party affiliated or connected to Navmii, as reasonable for business purposes, which may be located in the European Union and the U.S.A., potentially countries outside of your jurisdiction;
Navmii may also share personal information with companies or organisations connected or affiliated with Navmii, such as subsidiaries, sister-companies and parent companies;
Personal information may also be shared with Navmii’s trusted partners and service providers to process it for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures. For example, we use service providers to help us with customer services.
Please note that your username and some other information will be visible to others. Note that your username will be included along with any information you submit for posting (such as traffic reports or chat messages). It will therefore be visible to others.
Integration with social networks
You may choose to share information between your Navmii account and your social network account (such as Facebook). Through this option, you may choose to have personal information and other content about you available from social networks, transmitted and shared through the Services. Similarly, you may choose to have personal information and other content about you available from Navmii, including your location and route information, transmitted to and shared through your social network account.
When you connect to the social network account through the Services for the first time or otherwise make the Services interact with your social network account, you will be asked by the social network to permit the social network to share your personal information stored on such social network with Navmii. We collect your information from your social network account only in accordance with the permissions granted by you (such as your name, email address, list of friends, profile picture and other information available via the applicable social network).
You understand and agree that the Services may access, make available and store such information so that it is available on and through your Navmii Account, until your Navmii Account is deleted.
Please note that certain information which you have defined as private on your third party social network accounts may become public to other Navmii Users through the Services once you have allowed the social network to share such information with Navmii.
How Navmii retains data we collect
Some data you can delete whenever you like, some data is deleted automatically, and some data we retain for longer periods of time when necessary. This section describes why we hold onto different types of data for different periods of time.
Information retained until you remove it - such as your “Home, “work”, favorites, email address and other account related information. We’ll keep this data in your Navmii Account until you choose to remove it and/or update it.
Information retained until your Navmii Account is deleted - we may keep some data for the life of your Navmii Account if it’s useful for helping us understand how users interact with our features and how we can improve our services. For example, if you made an incident report, we will keep information about how many reports you have submitted, even after the event is removed. When you delete your Navmii Account, the information about how many reports you have submitted is also removed.
Information retained for extended time periods for limited purposes - sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. For example, when Navmii processes a payment for you, we’ll retain this data for longer periods of time as required for tax or accounting purposes. Reasons we might retain some data for extended periods of time include: Security, fraud & abuse prevention, Financial record-keeping, Complying with legal or regulatory requirements, Ensuring the continuity of our services, Direct communications with Navmii
How does Navmii use aggregated information?
Navmii may use anonymous, statistical or aggregated information (including anonymous location information), in a form that does not enable the identification of a specific user, to properly operate the Services, to improve the quality of theServices, to enhance your experience, to create new services and features, including customised services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes (including advertising).
Navmii may also use anonymous, statistical or aggregated information collected on theServices, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, to the Services’ providers, partners and any other third party. For example, GPS information that we receive from your mobile device may be provided to map editors in an aggregated and/or anonymous form to help improve the map and solve map problems, traffic data may be provided to cities, and aggregated ads analysis may be provided to advertisers.
Business partner that we work with who may use our aggregated data or display Ads in our applications:
Some of the cookies may expire when the session ends and you exit your browser.Other cookies are saved on your computer’s hard drive. If you wish to block theWebsite’s cookies, then please use the help button in your browser and follow the necessary instructions. However, bear in mind that disabling cookies may complicate or even prevent your use of the Website, or certain features thereof.
Navmii allows advertisers to run ad campaigns on the Services.
We don’t knowingly collect nor do we show you personalised ads based on sensitive categories, such as race, religion, sexual orientation, or health.
We don’t share information that personally identifies you with advertisers, such as your name or email, unless you ask us to. For example, if you see an ad for a nearby flower shop and select the “tap to call” button, we’ll connect your call and share your phone number with the flower shop.
As described under “When Navmii shares your information” section above, we work with other Google’s services (such asGoogle Doubleclick Bid Manager) for advertising and ad measurement purposes. In order to help advertisers decide what ads to show on Navmii, Google, and websites & apps that partner with Google, Navmii may share information with these services such as a unique identifier for advertising (Advertising ID available on Android mobile devices or similar technologies). You can learn more about how Google uses information from sites or apps that use its services and how you can control that in this page
The Ads personalisation control described above apply to personalised ads served by Navmii on the Navmii platform and they do not apply to ads served on third parties platforms, including on Navmii’s behalf.
It is clarified that we are not responsible for the content of said advertisements and the products delivered or services rendered thereby by third parties and you irrevocably and unconditionally agree that we shall not be held responsible or liable for any loss, damage, cost or expense that you may suffer or incur asa result or in connection thereof.
Navmii considers information security to be a top priority. Navmii services are built with strong security features that continuously protect your information. Navmii implements systems, applications and procedures to secure your personal information, to minimise the risk of theft, damage, loss of information, or unauthorised access or use of information. For example, we review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorised access to our systems. In addition, we restrict access to personal information to Navmii employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
The insights we gain from maintaining our services help us detect and automatically block security threats from ever reaching you.
However, these measures are unable to provide absolute assurance. Therefore, although Navmii takes great efforts to protect your personal information, Navmii cannot guarantee and you cannot reasonably expect that Navmii’s databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
Compliance & cooperation with regulators
We store data on servers located around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy.
When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.
If the European Union (EU) data protection law applies to the processing of your information, we provide the controls described in this policy so you can exercise your right to request access to, update, remove, delete, and restrict the processing of your information.
You also have the right to object to the processing of your information.
We process your information for the purposes described in this policy, based on the following legal grounds:
With your consent
We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. You can manage your settings at any time, including your in-app Privacy Settings.
When we’re pursuing legitimate interests
We process your information for our legitimate interests and those of third parties (such as partners including advertisers, in order to report use statistics)while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:
Providing, maintaining, and improving our services to meet the needs of our users
Developing new services and features that are useful for our users
Understanding how people use our services (including how they interact with our ads) to ensure and improve the performance of our services
Customising our services to provide you with a better user experience
Marketing to inform users about our services
Providing advertising to make our services freely available for users
Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our services
Protecting against harm to the rights, property or safety of Navmii, our users, or the public as required or permitted by law
Performing research that improves our services for our users and benefits the public
Fulfilling obligations to our partners like developers and rights holders
Enforcing legal claims, including investigation of potential violations of applicable Terms of Service
When we’re providing a service
When we’re complying with legal obligations
We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process.
If you have questions, you can contact Navmii and our data protection office, led by our Data Protection Officer, at: firstname.lastname@example.org. And you can contact your local data protection authority ifyou have concerns regarding your rights under local law.
Where you have the right to object to your personal data being used for ‘direct marketing’ and/or ‘host mailing’ purposes, you can change your options in relation to the information you wish to receive at any time by contacting our Compliance Officer in writing by post or email.
You have the right under the DPA to request from us information as to what personal data we are processing about you. Such requests should be made in writing by post or email to the Compliance Officer and should be accompanied by a £10.00 fee. We will provide you with the relevant information within 40 days of receipt of the fee.