[TeleNav PRIVACY POLICY]

Last updated on 24 June 2009.

All personal information and data from the European Union that TeleNav collects, uses, retains, and discloses in maintaining its Telenav Navigator product will be subject to this Privacy Policy. "Personal information" is defined as any information that identifies or can be used to identify a person to whom such information relates. Personal information does not pertain to "aggregate" or "anonymous" information, neither which is associated to a specific person or party. Your privacy is a high priority at TeleNav, and we go to great lengths to protect it. TeleNav respects your right to privacy, and shares your concern about any information you submit to us.

TeleNav adheres with the EU Safe Harbour framework as set forth from the US Department of Commerce regarding the collection, use, and retention of personal information and data from the European Union. We also follow the CTIA's Best Practices Guidelines for Location-Based Services.

Collection of Personal Information

We collect your personal information through three sources. TeleNav does not sell, rent, or share this information to third parties in other ways than disclosed in this privacy statement.

First, we collect information that you voluntarily chooses to share with TeleNav, such as information used to set up your account, for billing purposes, for customer support, or as part of the employment process with the company. When interacting with our customer service representatives, your written and oral communications may be recorded and/or monitored in order for us to provide a better level of service to you.

Secondly, we collect information that is automatically captured when you visit TeleNav websites (such as www.telenav.co.uk or www.telenav.eu) or use our services. Regarding the websites, the information is collected is on an anonymous basis and may include the time and date you visited the site(s), the pages you looked at, and your IP address and domain name. When you visit the TeleNav online shop at the above websites, a cookie will be stored on your computer, which is a small text file used to track your shopping cart on the site and also for shipping information.

When using the TeleNav Navigator service, we collect information such as your phone number; your first name, last name, and email address which are used on your behalf when you request to send another user an sms message from our application, such as via Shared Address; your User Preferences which are stored on the device such as but not limited to the display/audible language, measurement units for directions such as metric or Imperial, and navigation display style; the type and location of the wireless device(s) you use; calls and text messages you send and receive as related specifically to our product; and your speed, position, and direction. This information may be aggregated in an anonymous fashion.

The third way that we may collect your personal information is from third-party sources. For example, we may receive credit information from a third-party source in connection with employment review.

Use of Personal Information

We use personal information for a variety of business purposes to run the TeleNav Navigator service. For example, we use your information to complete transactions. While for credit-card processed transactions TeleNav does not store your credit card data, for other methods of payment we may retain billing-related personal information. For product marketing purposes, we use your information and input in order to improve our products and services, personalize the product, create product roadmaps, make company-level strategic decisions, and for other marketing purposes. We use your information to run the product itself: for example, in order to calculate your routes; generate maps; furnish traffic summaries and road condition reports; provide location-sensitive content such as businesses, events, services; and send sms alerts on your behalf, for example, when you choose to share an address or to receive commute alerts. We also use your personal information to provide customer support to your requests for further assistance. We retain personal information as for as long as we have a business need or as applicable laws, regulations, or government orders require. Personal information on backup and archive systems will be retained for a minimum of seven years.

Disclosure of Personal Information

We may sell, rent, or provide personal information to third parties under these conditions:

1. We have your consent.

2. We have been requested to do so by law.

3. We have determined that you have been in breach of the TeleNav Terms and Conditions or any of our policies or usage guidelines for our products and services.

4. We believe it is necessary in order to prevent, investigate, detect, or prosecute criminal offences or attacks against TeleNav sites or its network.

5. We believe it is necessary in order to protect the rights, property, or safety of TeleNav's employees, its customers, or the public.

6. We believe it is necessary in order to fulfill your product or service order. For example, TeleNav may contract an outside shipping company to fulfill your order and a credit card processing company to process your credit card information. These companies do not retain, share, store, or use your personally identifiable information for any other purpose. These companies also adhere to Safe Harbour privacy practices or at least provide the same level of privacy protection as required.

7. We believe it is necessary to create or improve our products and services.

8. In cases of business transfer, such as mergers and acquisitions.

Security and Integrity of Personal Information

Sensitive information (such as the submission of passwords or credit card information) is done via Secured Socket Layer (SSL). TeleNav does not retain any credit card data and passes all such sensitive data through a payment gateway for processing. Although we do not guarantee that loss, misuse, or alteration of your personal information will not occur, we strive to prevent such occurrences.

TeleNav protects your personal information in our hosted Data Centers in which physical and network access is strictly controlled. Data Centers hosting TeleNav customers are all rated as Tier-1/Commercial Grade, housing the Internet's largest websites, e-commerce, and online services. These data centers all follow rigid guidelines for access control and will only allow permitted TeleNav staff to enter the hosted premises.

All TeleNav staff involved with managing customer-facing systems is screened and has had criminal background checks completed. Each member of this staff sign an agreement before receiving access to production systems in which violations and failure to comply with policy will result in disciplinary actions, up to and including termination.

Choice and Access

TeleNav recognizes the responsible use of information that is collected on its site and in the connection of its products and services. You may access and modify your contact information by sending us an email through the Send Feedback and Contact Us pages on the TeleNav websites www.telenav.co.uk or www.telenav.eu); by sending an email to our support representatives at eusupport@telenav.com ; or by calling us at + 44 20 7519 5052 (UK), + 49 30 7576 3295 (Germany), or + 34 911 89 8181 (Spain).

You may opt-out selectively or generally to our marketing communications; however, if you purchase or continue to subscribe to our products and services, you will continue to receive invoices, transactional notices, or other similar communications. Some features of the TeleNav Navigator, such as various navigational and traffic alerts we provide, use text as a mode of communication. If you wish specifically to opt-out of all sms messages from us, please send a text with the words STOP to the short code 69355. We will remove your information within approximately 10-15 business days.

If you choose to submit a product testimonial to us at our websites, please indicate if you do not want TeleNav to publish your testimonial or wish only to employ your initials instead of your name. Please note that any information you post, however, to a community site such as a public bulletin board, blog, chat room, public help, wikis, user profiles, and the like, is available to all persons accessing that location.

Enforcement

You have the right to amend, correct, change, or delete contact information where inaccurate. TeleNav will make good faith efforts to verify and remedy requests of inaccurate contact information except where the request is unreasonable, or threatens the privacy of others. If the request requires a disproportionate amount of technical effort or expense, TeleNav may charge a fee to cover the cost of providing such access and may limit the number of times within a given period that access requests from a particular individual will be met.

Policy Updates and Contact Information

We may update this policy from time to time due to a material change in our practices or due to legal or regulatory changes. If we choose to use or disclose personal information in a way that is materially different from that which was stated in this policy at the time your personal information was collected, we will give notice by posting changes to this policy to TeleNav's website(s) in a timely manner; and you will receive an opportunity to opt-out of the proposed use or disclosure of your personal information.

In order to comply with the European Union's Safe Harbor Principles, TeleNav commits to the resolution of complaints about your privacy and our collection or use of your personal information. We have committed to resolve any complaints by European Union citizens relating to this policy, which cannot be resolved directly with our company, through BBB EU Safe Harbor, a dispute resolution procedure administered by the Council of Better Business Bureaus, Inc.

TeleNav takes its users' privacy concerns seriously, and if you believe that TeleNav has not complied with this Privacy Policy in regards to your personal information, you may write to the TeleNav Privacy Officer at the following address:

TeleNav Headquarters
ATTN: PRIVACY POLICY OFFICER
1130 Kifer Road
Sunnyvale, CA 94086 USA

Email: safeharbour@telenav.com

In your letter, please describe in detail -- in as much detail as possible -- the ways in which you believe that we have not complied with this Privacy Policy. We will investigate and verify your complaint in a timely manner. If you do not receive acknowledgement of your complaint or if you feel that your complaint is not adequately addressed by TeleNav, you should then contact:

Council of Better Business Bureaus, Inc.
BBB EU Safe Harbor
4200 Wilson Boulevard, Suite 800
Arlington, VA 22203
Phone: 703-276-0100
Web: www.us.bbb.org
Email: eusafeharbor@council.bbb.org