Navigation — GM 2020 — Southeast Asia

Telenav Privacy Policy for Navigation and OnStar Connected Navigation

This Privacy Policy governs your use of Navigation, OnStar Connected Navigation, or both services when used together that are offered by Telenav, Inc. (“Telenav”) for select automotive vehicles produced or distributed by General Motors Holdings LLC or its affiliates (“GM”).  In order to provide you with navigation and related services, we collect and store certain information relating to your account, your location, and your use of the navigation services.  Please review this Privacy Policy for more detail about the information that may be collected and used in connection with your use of Navigation, OnStar Connected Navigation, and OnStar Connected Navigation with Predictive Navigation. If you do not agree with the terms of this Policy, please do not engage in any of these activities.

Telenav understands and respects your concerns about the use of your personally identifiable information, collected from you as a user of Navigation and/or OnStar Connected Navigation ("Personal Information"). Personal Information includes name, home address, telephone numbers including mobile telephone numbers, email addresses, and VIN numbers. Personal Information does not include anonymous or aggregate information, which after processing cannot be associated with a specific person or entity. We believe that you should know what information about you we collect, as well as how that information is used, maintained, and, in some cases, shared. The following sets forth our privacy practices and policies, applicable to Navigation and OnStar Connected Navigation users.

You acknowledge and understand that this Privacy Policy does not apply to other Telenav products or services, our business partners or other companies that Telenav does not own or operate. For information about other Telenav products and services as well as the Telenav.com website, please visit https://www.telenav.com/legal/policies. For information on how other providers of products or services handle Personal Information you provide through other web sites or through the use of our services in conjunction with a third party, please consult their privacy policies.

INFORMATION COLLECTED ABOUT YOU AND OUR USE OF SUCH INFORMATION

The types of personal and other information we may collect about you are primarily from two sources: (1) information you provide; and (2) information automatically collected. How we use and maintain that information is described below.

1. Information You Provide

(a) Register/Information Related to Your Account

We receive and store Personal Information about you when you authorize our business partners to share that information with us for use with Navigation and/or OnStar Connected Navigation or login to Navigation or OnStar Connected Navigation using your information, and when you otherwise transmit such information to us via OnStar Connected Navigation, or contact us by phone or email regarding our products and services. For instance, to maintain and/or verify your account we may receive certain account information from other of your accounts, with your consent, including your name, email address, vehicle information and whether your OnStar Connected Navigation subscription is active. We may also assign you a separate and unique Telenav ID number, which may be stored and used to manage your account and provide you with customer support, and to perform research and analysis about your use of our products and services.

Through GM, Navigation and/or OnStar Connected Navigation, you have the option of providing us with your home and work addresses, which we store in our database, to enable you to quickly navigate to those destinations and readily access other features of Navigation and/or OnStar Connected Navigation. Through Navigation or OnStar Connected Navigation you can also create a list of "favorite" addresses and points of interest. Within Navigation and/or OnStar Connected Navigation you also have the option to use the Navigation and/or OnStar Connected Navigation settings menu to customize your experience, for example by selecting your navigation preferences, setting up traffic reports, and selecting your preferred gas grade for searches. For OnStar Connected Navigation subscribers, we store these addresses and setting preferences in our cloud database so that you can access them from Navigation and/or OnStar Connected Navigation. For Navigation users, this information is stored locally on the navigation system in your vehicle.

We may also use the information that we collect about you to manage your account and provide you with customer support, perform research and analysis about your use of our products and services, to inform you from time to time within Navigation and/or OnStar Connected Navigation about products or services that we think may interest you, unless you inform us that you opt out from receiving such communications.  We may share certain information we collect about you and your usage activity that does not include Personal Information with GM on a basis for the purpose of performing research and analysis about users of its products and services.

(b) Contact Our Customer Service Representatives/ Feedback

GM may use your email address or phone number to contact you with regard to Navigation or your OnStar Connected Navigation subscription, such as to communicate that it is about to expire or to respond to any inquiry or feedback you submit with GM Customer Service Representatives, by email or from within Navigation and/or OnStar Connected Navigation.

If you provide feedback regarding a routing or map issue, we may share your comments and anonymized location data with our third party map provider.

(c) Request for Information

When you request additional information about Navigation or OnStar Connected Navigation, the information collected through these requests may include your name, phone number, and email address. We will use this information to provide you with details about these services, and in accordance with requirements under applicable law, we may use this information to promote our services to you in the future, unless you inform us that you opt out from receiving such communications.

(d) Public Forums

If you use or link to public forums such as social networking services, blogs on Telenav or non-Telenav websites, internet bulletin boards, or chat rooms, be aware that any Personal Information you submit can be read, collected, or used by other users of these forums, including to send you unsolicited messages. Telenav cannot prevent the distribution and use of such information by other parties.

2. Information Automatically Collected

We automatically receive certain types of information, some of which may be associated with Personal Information, when you use either Navigation or OnStar Connected Navigation or both services.

(a) Information Related to Your Location and Route or Other User Content

Each time you access Navigation, we record your location, search and route information, including your point of origin or current location, the address of your destination, the starting time of your trip, and the route you are instructed to follow. When you are in an active Navigation session, we periodically record your current location, data from your vehicle’s sensors, and GPS heading and speed from the GPS hardware associated with your vehicle in order to provide you with your route. Navigation will save and display your most recent destinations to allow you to easily navigate to these destinations again.

When you choose to use your current location for specifying the locale for a business finder search, or obtaining a map, we use your location information for the requested purpose, and then discard it. We anonymously record any search activities and results for comparative analysis.

For OnStar Connected Navigation users with an active subscription who have opted-in to use connectivity, this location and route information will be stored in our secure cloud database, where we may keep such information for up to five years to improve our services and to provide other features that may enhance our service capabilities, functions, and your user experience.  For OnStar Connected Navigation users, other address data, including home and work addresses, favorite places, and recent destinations will also be stored with your account information in our secure cloud database until your account is deleted.

For OnStar Connected Navigation users who have enabled the Predictive Navigation functionality, we will regularly receive and record location data from your vehicle’s GPS hardware, whenever you are operating your vehicle.  This data will be stored in our secured cloud database and we will use such information to customize and improve your navigation and search experience and our services, for example to provide preferred brand point of interest search results, personalized routing, and commute alerts.

You can update your Predictive Navigation options (including disabling Predictive Navigation) at any time by accessing the Navigation Settings menu.

(b) Information About Your Vehicle Systems

We may receive and store limited vehicle data from the vehicle systems, for example, ambient temperature, seat sensors on/off, and ignition on/off, which may be used to optimize the safety functionality of Navigation.  For Navigation-only users, this data will be stored indefinitely in your Navigation system’s local memory.  For OnStar Connected Navigation users with an active subscription, this data will be stored in our secure cloud database for up to five years from the date of collection.

(c) Information About Your Use of Navigation Services

When you use either Navigation or OnStar Connected Navigation or both services together, we log certain information relating to your use of each of Navigation and OnStar Connected Navigation and the Navigation performance. For example, we may collect data about what actions you take within a session, such as the type of search you performed or what kind of route you selected.

(d) Other Information

When you use the voice command or entry features on our services, we receive the text transcription from your audible utterance (what you said) and that text data may be stored for up to five years.

WHEN YOUR INFORMATION WILL BE SHARED OR DISCLOSED

Telenav does not sell, rent, license or otherwise share information relating to your use of Navigation or OnStar Connected Navigation with unaffiliated parties except as explained in this Privacy Policy, or as otherwise required or permitted by applicable law.

Consent Given/Transaction Processing

We may disclose Personal Information about you to third parties who complete transactions or perform services on our behalf.  Your use of the Navigation and/or OnStar Connected Navigation may constitute consent to such disclosure.

Third Party Services or Third Party Service Providers

Telenav share certain information that is not Personal Information with strategic partners that work with us to analyze usage, provide and improve products or services, or that help us market to customers, or for similar purposes. Information that is not Personal Information is not subject to any restrictions of use or disclosure under this Privacy Policy.

Some of the Navigation and OnStar Connected Navigation services and functionality are provided by or in conjunction with third party service providers. These third party service providers process Personal Information on our behalf and are obligated to process such information in compliance with this Privacy Policy and other appropriate security and confidentiality measures. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes. Personal information may be maintained and processed by us, our affiliates and other third party service providers in the US or other jurisdictions.

Legal Processes

We, our affiliates and service providers will comply with any applicable subpoenas, court orders or other legal processes for information about you in our possession, and we may use and disclose Personal Information to establish or exercise yours, ours, or others' legal rights, or to defend against legal claims. We also may be required to disclose Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Business Transfers

Information about you in our possession may be disclosed as part of a prospective or completed merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the unlikely event of insolvency, bankruptcy, or receivership in which your Personal Information would be transferred as one of the business assets of the company. Telenav does not guarantee that any entity receiving such information in connection with one of these transactions will comply with all terms of this policy.

SECURITY OF PERSONAL INFORMATION

Telenav has implemented various physical, electronic and procedural safeguards in an effort to protect the confidentiality and security of Personal Information in our custody and under our control. For instance, Telenav limits access to Telenav systems that store such information to authorized personnel.

While Telenav maintains a multitude of security measures to prevent unauthorized access to or disclosure of your Personal Information, no security measures are absolute or wholly guaranteed. Telenav will make reasonable attempts to notify you if it determines there were unauthorized acts by third parties that violate the law or this policy, or other security breaches, or where otherwise required by law.

Telenav will maintain your Personal Information for as long as a business need exists, or as required by applicable laws, regulations, or government orders. When we dispose of Personal Information, we use commercially reasonable procedures to erase, anonymize or render it unreadable.

CHILDREN'S PRIVACY

Telenav will not knowingly request or collect Personal Information from any person under 13 years of age without prior verifiable parental or legal guardian consent. If, however, you authorize a child to use our services or products by providing them access to a vehicle or device with access to Navigation, OnStar Connected Navigation or other Telenav services or products, any Personal Information associated with such use will be treated as your information in accordance with this policy. Telenav encourages parents to be involved in the online activities (including wireless Internet browsing) of their children to ensure that no information is collected from a child without parental or Guardian consent.

CUSTOMER REQUESTS FOR INFORMATION

Customers are entitled to request information concerning whether a business has disclosed Personal Information to any affiliated companies or third parties for their direct marketing purposes. Customers are further entitled to request access to their Personal Information under Telenav's control and to update and correct inaccuracies in such Personal Information. To protect your privacy and security, Telenav will take reasonable steps to verify your identity before providing you access or making corrections. Good faith efforts to resolve requests to correct inaccuracies in Personal Information will be made by Telenav, except where the request is unreasonable. As stated in this Privacy Policy, Telenav will not sell or share your Personal Information with third parties for their direct marketing purposes without your consent. Customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices and policies may contact us at support@telenav.com or write to the attention of Privacy Policy Officer, Telenav, Inc., 4655 Great America Parkway, Suite 300, Santa Clara, CA 95054, USA.

CHANGES TO THIS POLICY

Telenav may from time to time update this Privacy Policy, and we encourage you to periodically review this Privacy Policy to be informed of the latest changes. In the event that Telenav merges with, or is acquired by another company, a change to this Privacy Policy may result.

OTHER AGREEMENTS

Telenav may enter into written product or service agreements with customers that contain specific provisions related to confidentiality, security or other handling of information. If this Privacy Policy conflicts with any provision of those terms and agreements (both US and international), those terms and agreements govern to the extent of the inconsistency. In all other instances, the terms of this Privacy Policy apply.

GOVERNING LAW

By choosing to use either Navigation or OnStar Connected Navigation or both services together, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the State of California, United States of America. Except where prohibited by applicable law, you also agree to arbitrate such disputes and to abide by any limitation on damages contained in our Terms of Use, Terms and Conditions of Service, or other applicable agreement we have with you.

UPDATE INFORMATION / REVOKE CHOICES / SUGGESTIONS / CONTACT INFORMATION

If you would like to access, update or correct any information that you have provided to Telenav through your use of Navigation or OnStar Connected Navigation or to delete any information associated with your ID (subject to any legal obligation we may have to maintain such information), or if you have suggestions for improving this Privacy Policy, please send an e-mail to ConnectedNavCare@telenav.com or contact our Privacy Policy Officer at the contact information set out below. We will provide you with access to your Personal Information (subject to limited exceptions set out under applicable law) and use reasonable commercial efforts to address any concerns that you may have.

CONTACT INFORMATION FOR INTERNATIONAL USERS:

Telenav commits to resolve complaints about your privacy and our collection or use of your Personal Information.  Individuals with inquiries or complaints regarding this Privacy Policy should first contact Telenav at:

Telenav, Inc.
ATTN: PRIVACY POLICY OFFICER
4655 Great America Parkway, Suite 300
Santa Clara, CA 95054
USA
Email: support@telenav.com

If you believe that Telenav has not complied with this Privacy Policy in regard to your Personal Information, you may write to the Telenav Privacy Officer at the above address. 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.

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