TELENAV PRIVACY POLICY

CONNECTED NAVIGATION AND INTELLIGENT MOBILITY FEATURES

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Updated On: v3.0_August 2025

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This Telenav Privacy Policy ("Policy") governs your use and access of certain services, products, or websites that we offer, including those provided with or through our affiliates. The protection of your personal data is a key priority for Telenav, Inc., a global provider of location-based services and connected navigation solutions, with its registered office at 2540 Mission College Boulevard, Suite 100, Santa Clara, CA 95054 ("hereinafter Telenav", "we", "us", "our").

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The Original Equipment Manufacturer ("OEM"), our partner in delivering connected vehicle solutions, acts as the Data Controller and is responsible for determining the purposes and means of processing personal data. This Policy outlines how personal data is collected, used, shared, and protected in connection with these services, in compliance with Applicable Data Protection Laws.

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SCOPE OF THE POLICY

This Policy applies to all end-users of the services, including the Navigation Service, Advanced Driver Assistance Systems (ADAS), Intelligent Speed Assistance (ISA), Google Search Module as part of the Navigation services, and any other services integrated into vehicles provided by the OEM, sold or operated in any jurisdiction worldwide where these services are available. The specific services accessible to you depend on the OEM’s integration choices, ensuring a tailored experience aligned with your vehicle’s capabilities and relevant jurisdiction. If you do not agree with the terms of this Policy, please refrain from using the connected navigation services.

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By using or accessing our services, products features, website, or otherwise by interacting with us via our software (hereinafter "Telenav Software"), you acknowledge this Policy and agree to be subject to it. If you do not agree to this Policy, you are not entitled to use our services, products, or website(s). You acknowledge and understand that this Policy does not apply to our business partners or other companies that Telenav does not own or operate. For information on how our business partners and other companies process your Personal Data (as defined below), please consult their privacy policies. Information on the processing activities undertaken by the OEM you may find in their privacy policy made available to you in the vehicles.

We are committed to protecting and respecting your privacy. This Policy describes our approach to data protection, data privacy and data security, including our compliance with various governmental regulations and requirements, and explains why and how we may collect, store, process, and distribute your Personal Data to third parties. We also describe in this Policy your rights in relation to that information.

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ROLE OF THE PARTIES:

• The OEM serves as the Data Controller, determining the purposes and means of processing your personal data in connection with the delivery of the connected navigation services. Details of the data processing activities undertaken by the OEM are provided in their separate privacy policy, which is made available through your vehicle or related services. 
• Telenav acts as the Data Processor, processing personal data solely on behalf of and under the documented instructions of the OEM, in compliance with a Data Processing Agreement (DPA) that incorporates appropriate safeguards, such as Standard Contractual Clauses (SCCs), where required under Applicable Data Protection Laws, including the General Data Protection Regulation (GDPR) where relevant. In limited instances unrelated to the core navigation services, Telenav may act also as an Independent Data Controller, such as when processing anonymized or aggregated statistical data to improve its services or address technical issues, with no connection to identifiable users or the OEM’s purposes. These activities are addressed within this Privacy Policy.

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By "Applicable Data Protection Laws" we may refers to any laws, regulations, or legal frameworks enacted by a recognized governmental or administrative authority, aimed at safeguarding the privacy and data protection rights of individuals or households. These laws apply in the jurisdictions where our product is downloaded, accessed, or used by individuals, as determined by the Original Equipment Manufacturer (“OEM”). Such jurisdictions may include, but are not limited to, the European Union, the United Kingdom, Brazil, Australia, the Middle East, North America, Asia-Pacific, Africa, and other regions globally. This term encompasses prominent data protection frameworks such as the General Data Protection Regulation (Regulation (EU) 2016/679, known as GDPR) in the European Union, the UK General Data Protection Regulation (known as UK GDPR) in the United Kingdom, the Lei Geral de Proteção de Dados Pessoais (Law No. 13,709/2018, known as LGPD) in Brazil, the Privacy Act 1988 (as amended) in Australia, and the Personal Data Protection Law (Royal Decree M/19 of 2021, known as PDPL) in Saudi Arabia as an example from the Middle East. It also includes other major global privacy laws, such as the California Consumer Privacy Act (as amended by the California Privacy Rights Act, known as CCPA/CPRA) in California, USA, the Personal Information Protection and Electronic Documents Act (known as PIPEDA) in Canada, the Personal Information Protection Law (known as PIPL) in China, the Digital Personal Data Protection Act, 2023 (known as DPDPA) in India, the Protection of Personal Information Act, 2013 (known as POPIA) in South Africa, the Personal Data Protection Act 2012 (known as PDPA) in Singapore, and the Act on the Protection of Personal Information (known as APPI) in Japan. Additionally, it covers similar laws in other jurisdictions, including the United Arab Emirates (Federal Decree-Law No. 45 of 2021, Israel (Protection of Privacy Law 5741-1981 and Data Security Regulations 5777-2017), and Thailand (Personal Data Protection Act B.E. 2562 with amendments in 2025). 

The term further extends to any other applicable data protection laws in jurisdictions where the OEM makes the product available, ensuring comprehensive global coverage as privacy regulations evolve. 

Unless otherwise specified in this Policy, Telenav acts as a data processor with respect to the Personal Data we collect, store, process, or share in accordance with this Policy. 

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For any questions or requests regarding this Policy, please refer to Section 10 ("Contacting Telenav") below.

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1. INFORMATION COLLECTION AND OVERVIEW OF OUR PRODUCTS AND FEATURES

Based on how you engage with our services, we collect various types of information from multiple sources to provide a tailored and effective user experience. You may directly provide certain information, such as when you input data for navigation purposes, like planning a route using your current location or searching for nearby points of interest. Additionally, we may indirectly gather information through your interaction with our connected navigation service, referred to as the (“Navigation Service”), and other integrated features or products. 

Depending on the configuration chosen by the OEM and the relevant jurisdiction, some or all of the following products and features may be incorporated and utilized: 

(i) the Navigation Service –which may include Predictive Navigation, Google Search, User Feedback, Probe Data, and User Behavior Analytics, (ii) our Advanced Driver Assistance Systems (ADAS), (iii) Intelligent Speed Assistance (ISA), (iv) the Google Search Module or (v) Dead Recognition (“DR”). The specific features available to you will depend on the OEM’s integration decisions, ensuring a customized experience that aligns with the capabilities of your vehicle or device.

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Below, we outline how data is collected and used across these features to deliver a seamless and optimized user experience while ensuring the protection of your personal information.

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1. Connected Navigation Services are designed to enhance your travel experience by providing core functionalities, including route planning, real-time traffic updates, and point-of-interest searches. It generates optimized routes tailored to your preferences, such as the fastest, shortest, or most fuel-efficient paths, ensuring efficient travel planning. The service delivers real-time traffic updates by monitoring road conditions, congestion, closures, or accidents, allowing for proactive route adjustments to minimize delays. Additionally, the point-of-interest search functionality enables you to find nearby destinations, such as restaurants, gas stations, or landmarks, by presenting relevant and prioritized results based on your location and search inputs. These features work together to offer a seamless, adaptive, and user-friendly navigation experience. Users are encouraged to verify route suggestions and traffic information against current road conditions to make safe and informed travel decisions.

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Categories of personal data processed: When and if you use the Navigation Service on your vehicle in connected mode to search for a point of interest, route, or address, we receive, store, and process (i) a unique identifier assigned by the OEM; (ii) your current GPS location search histories and route information, including your point of origin or current location, the address of your destination, the starting time of your trip, your points of interest, and other similar saved data; (iii) your address or point of interest search requests and search results selections; (iv) and information about your use of the location and routing search service, its performance and your related actions and selections. 

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2. Features designed for electric vehicle (EV). Telenav Software utilizes collected data to enhance the user experience by enabling features tailored to EV-specific needs. This includes robust search capabilities for locating EV charging stations, brand-specific searches to identify preferred charging networks, and real-time monitoring of the EV's battery status. When the battery reaches a critical level, the low battery detection alarm leverages this data to automatically suggest the nearest available charging station, ensuring users remain informed about recharging options. The software also estimates and displays the EV’s range on the map and route, offering valuable insights for travel planning. The EV trip planner uses current battery endurance data to optimize navigation by incorporating strategically planned charging stops, which users can add to their route with a single click, streamlining their journey. Additionally, the software provides high-speed and urban differentiated endurance estimations for informational purposes, relying on collected data to offer general guidance for route planning in various driving scenarios. Users are advised to consider real-time factors such as driving conditions, weather, and personal driving habits and to exercise caution when relying on these estimations for real-time decision-making. For a safe and reliable journey, users should make travel decisions by considering multiple factors beyond the software’s estimations.

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Categories of personal data processed: When and if you use the Navigation Service on your vehicle in connected mode to access electric vehicle (EV)-specific features, such as searching for EV charging stations, utilizing the EV trip planner, or monitoring battery status, we receive, store, and process the following categories of personal data: (i) a unique identifier assigned by the Original Equipment Manufacturer (OEM), such as a hashed vehicle identification number (VIN); (ii) your current GPS location, search histories, and route information, including your point of origin or current location, the address of your destination, the starting time of your trip, points of interest (e.g., charging stations), favorites, pre-set Home/Office addresses, and other similar saved data; (iii) your search requests for addresses or points of interest, including brand-specific EV charging station searches, and your selections from search results; (iv) information about your use of the EV-specific features, such as navigation usage history, real-time battery status, power capacity, current power percentage, car model, and interactions with features like the low battery detection alarm or high-speed/urban endurance estimations; (v) and data related to the performance of these services, including your actions and selections, such as adding suggested charging stations to your route or utilizing the EV trip planner for optimized navigation with charging stops.

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3. The Advanced Driver Assistance Systems (ADAS) feature collects and processes data to enhance driving safety and convenience. By leveraging vehicle sensor data, geolocation information, and real-time environmental inputs, ADAS provides functionalities such as lane departure warnings, adaptive cruise control, and collision avoidance support. This feature uses data from your vehicle’s sensors and navigation inputs to detect road conditions, traffic signs, and nearby obstacles, delivering timely alerts to promote safer driving decisions. For example, ADAS may process data on lane markings or vehicle proximity to provide visual or audible cues, helping you maintain proper lane discipline or avoid potential collisions. The system continuously refines its performance by analyzing driving patterns and environmental data, ensuring a responsive and tailored experience. Users are encouraged to remain vigilant and consider external factors such as road conditions and traffic dynamics, using ADAS as a supplementary tool rather than a sole decision-making resource for safe driving.

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Categories of personal data processed: When and if you use the Advanced Driver Assistance Systems (ADAS) feature in your vehicle, the following categories of data are collected and processed to enhance driving safety and convenience: (i) vehicle sensor data, including information from cameras, radar, lidar, and ultrasonic sensors, capturing details such as lane markings, vehicle proximity, and obstacle detection; (ii) geolocation information, including your vehicle’s current GPS coordinates to contextualize road conditions and environmental factors; (iii) real-time environmental inputs, such as traffic sign data, road surface conditions, and weather-related information obtained from external feeds or vehicle sensors; (iv) driving pattern data, including speed, acceleration, braking, and steering behavior, to refine system performance and tailor alerts; (v) and system interaction data, such as user responses to ADAS alerts (e.g., acknowledging lane departure warnings or engaging adaptive cruise control), to improve functionality and responsiveness. These data categories are processed to enable features like lane departure warnings, adaptive cruise control, and collision avoidance support, but do not include personally identifiable information (PII) unless explicitly linked to other identifiable data by the Original Equipment Manufacturer (OEM

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4. The Intelligent Speed Assistance (ISA) feature utilizes data to promote compliance with speed limits and enhance road safety. By integrating geolocation data, real-time traffic information, and speed limit databases, ISA informs drivers of applicable speed limits based on their location and provides alerts when exceeding these limits. The system may also adjust vehicle speed in certain scenarios, depending on the vehicle’s configuration and user settings, to help maintain compliance with local regulations. Data collected through ISA, such as current speed, road type, and traffic conditions, is used to deliver accurate and context-aware speed recommendations. This feature aims to reduce the risk of speeding-related incidents while supporting a smoother driving experience. Drivers should remain aware of real-time road conditions and exercise judgment, using ISA as a supportive tool rather than a definitive guide for speed-related decisions.

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Categories of personal data processed: When and if you use the Intelligent Speed Assistance (ISA) feature in your vehicle, the following categories of data are collected and processed to promote compliance with speed limits and enhance road safety: (i) geolocation information, including your vehicle’s current GPS coordinates to determine applicable speed limits based on your location; (ii) speed limit database information, referencing local regulatory speed limits for specific road types and areas. These data categories are processed to enable features like speed limit alerts and, where applicable, automatic speed adjustments, but do not include personally identifiable information (PII) unless explicitly linked to other identifiable data by the Original Equipment Manufacturer (OEM).

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5. The Google Search Module The Google Search Module integrates advanced search capabilities into our navigation software, enabling users to perform detailed queries for points of interest, destinations, EV charging stations, or other relevant information directly within the Navigation Service. To provide accurate and contextualized results, the module processes certain categories of data, such as your search queries, geolocation, user preferences, and interaction data (e.g., clicks on results or predictive search engagements). For example, when you search for a nearby restaurant or charging station, the module processes your location and query details to return tailored suggestions, which may include business hours, ratings, availability, or other relevant attributes.

The data collected is also used to enhance the functionality of predictive search, refine results based on user behavior, and improve the overall accuracy and efficiency of the service. 

Some of your information, such as search queries and location context, may be transmitted to Google or other third-party service providers in order to fulfill your request. In these cases, such third parties may process your data under their own terms and policies. Specifically, Google may process personal data it receives as an independent data controller, including for purposes such as improving its services, personalizing content or ads, and analyzing online behavior. The applicable Google terms also clarify that data processed through Google Maps Platform services (including Search) may be transferred to, stored in, or otherwise processed on servers located outside the EEA, including in the United States, subject to Google’s data transfer mechanisms and compliance with applicable data protection law (for example, use of Standard Contractual Clauses as described in Google’s EEA Terms).

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The use of Google search features and content is subject to the then-current versions of the: (1) Google Maps End User Additional Terms of Service at https://maps.google.com/help/terms_maps/; and (2) Google Privacy Policy at https://policies.google.com/privacy.

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Categories of personal data processed: When and if you use the Google Search Module integrated into the navigation software, the following categories of data are collected and processed to provide personalized search results: (i) search queries, including terms entered for points of interest, destinations, or EV charging stations; (ii) geolocation information, such as your vehicle’s current GPS coordinates to contextualize search results; (iii) user preferences, including selected search results or settings that refine suggestions; (iv) and interaction data, such as clicks on search results or predictive search engagements, to improve result accuracy. These data categories enable tailored suggestions, such as restaurant details or charging station amenities, but may include personally identifiable information (PII) like search queries or location, which are protected through encryption and data minimization practices, as outlined in our privacy policy.

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6. The Dead Reckoning (“DR”) feature enhances navigation accuracy by estimating a vehicle’s position when GPS signals are weak, obstructed, or temporarily unavailable. By integrating data from onboard sensors such as speed, direction, and gyroscope readings, DR calculates the vehicle’s movement and continuously updates its position on the map. This ensures that navigation guidance remains available in tunnels, urban canyons, underground parking areas, or other environments where satellite signals may be interrupted. Data processed through DR, including vehicle speed, direction of travel, and distance covered, is used solely to maintain continuity of navigation services. This feature is designed to provide drivers with a seamless navigation experience, even in challenging environments. Drivers should continue to monitor their surroundings and exercise judgment, as DR serves as a supportive tool and may not always reflect exact positioning in real time.

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Categories of personal data processed: When and if you use the Dead Reckoning (DR) feature integrated into the navigation software, the only category of data collected and processed is your vehicle’s GPS position, which is used solely to maintain accurate navigation guidance when satellite signals are weak or temporarily unavailable

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Across all features—Navigation Service, ADAS, ISA, DR and/or the Google Search Module—data is collected and processed to improve functionality, safety, and user experience. Unless otherwise specified in this Policy, Telenav acts as a data processor with respect to the Personal Data we collect, store, process, or share. For any questions or requests regarding this Policy or data usage, please refer to Section 10 ("Contacting Telenav") below.

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2. DATA SUBJECTS

This Privacy Policy applies to the following categories of data subjects:

1. Drivers and users of the vehicles: individuals who interact with the Telenav navigation system embedded in the OEMs vehicles while driving or using the services (e.g., owners, authorized drivers, rental users, etc.);
2. Individuals submitting feedback or support requests: users who contact Telenav via available support channels (including in-vehicle forms, app feedback tools, or external communication) for inquiries, complaints, or assistance;
3. Vehicle occupants generating navigational or diagnostic data: passengers or secondary users whose movements or usage patterns may be indirectly reflected in location, sensor, or application data processed by Telenav.
4. Data subjects identified via regulatory or legal proceedings: any individuals whose personal data becomes relevant due to legal, compliance, or regulatory inquiries or complaints, where Telenav is required to process or respond;

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3. CATEGORIES OF PERSONAL DATA PROCESSED
   
   1. Telenav as processor:

When you use Telenav Software, we may processes the following categories of personal data on behalf of the Data Controller for the purposes described in the OEM’s privacy policy:

1. Identifiers and technical metadata: a unique user or session identifier assigned by the OEM; system-generated metadata related to the use of the navigation system;
2. Geolocation and routing information: current GPS location of the vehicle; planned route and real-time navigation path; point of origin and destination address; estimated trip start time and duration; routing instructions provided to the user;
3. Search and interaction data: search inputs (e.g., address, place name, or category of interest); selected search results (e.g., chosen POIs or routes); user selections and interactions with the search and routing features;
4. Historical navigation data: previous search histories and navigation destinations; frequently used or saved locations (e.g., Home, Office); historical trip and route data retained for service functionality;
5. Preference and personalization data: pre-set preferences within the navigation service; ser-defined favorites or customized navigation settings.
6. Vehicle sensor and status data: speed, heading, and engine on/off status from the vehicle’s sensors or GPS hardware; battery level or range status (particularly relevant for electric vehicles); diagnostics data (e.g., related to navigation system performance or errors).

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Depending on the configuration, the above data may be stored either locally in the vehicle system or securely in Telenav’s cloud infrastructure in compliance with applicable data protection safeguards.

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2. Telenav as controller

In limited and specific cases unrelated to its role as a Data Processor, Telenav may process personal data as an independent Data Controller, solely for purposes it determines itself (e.g., system improvement, analytics, and support) described in this Privacy Policy. In these cases, data is processed in a pseudonymized or anonymized format and is not used to identify or target individual users (hereinafter the “Personal Data”).

1. Vehicle sensor and status data – pseudonymized or anonymized: speed, heading, engine on/off status, EV battery level/range, and diagnostics data;
2. Device and application usage data – pseudonymized or anonymized: feature usage frequency, session duration, crash logs, and error reports;
3. Connectivity and network information – pseudonymized: network type (Wi-Fi/cellular), connection status, and pseudonymized IP address;
4. Inferred or derived data – anonymized: aggregated routing behavior, statistical usage trends, and trip summaries not linked to individuals;
5. User support or feedback submissions – pseudonymized if email provided, otherwise anonymized: feedback content, contact email (if voluntarily submitted);
6. System configuration and device metadata – pseudonymized or anonymized: OS version, firmware, app build number, head unit model, language, and region settings;
7. Localization and time zone data – anonymized: system-inferred locale and time zone settings used to localize content and formatting;
8. Telemetry or sync events – anonymized: timestamps of sync events, update/download success/failure status, cache refresh logs;
9. In-app diagnostic flags or silent events – anonymized: internal QA flags, debug event markers, feature activation states used for stability testing;
10. Security incident metadata – pseudonymized or identified: IPs, access timestamps, anomaly logs, and affected system components; affected data subjects; level of negative impact;
11. Access and activity logs (audit trails) – pseudonymized or identified: admin actions, access history, configuration change logs;
12. Data subject identity information – identified: name, email, request metadata, and related correspondence/information collected via other calls/chats when handling GDPR rights or other complaints related to Telenav operations as controller;
13. Complaint submission data – identified: complainant identity, summary of issue, submitted documents or screenshots, and response history; status of complaint management; any data listed herein or otherwise provide by the 
14. Investigation and regulatory correspondence data – identified: regulatory inquiry files, internal assessments, and supervisory authority communications;
15. Authentication and authorization data – pseudonymized or identified: login credentials (hashed), session tokens, MFA logs, user roles or access permissions;
16. Consent and preference records – identified or pseudonymized: opt-in/opt-out logs, consent timestamps, and stored feature preferences;
17. Legal retention and archiving metadata – pseudonymized or anonymized: archive flags, data retention events, file deletion or expiration logs.

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4. DATA SOURCES

When Telenav processes your personal data as an independent data controller, we may collect such data from the following sources, depending on the context of your use of the Telenav Software or navigation services:

1. directly from you: we collect information you voluntarily provide, such as when submitting support requests, giving feedback, or configuring in-app settings (e.g. saving destinations or preferences);
2. from your vehicle systems: data such as GPS location, speed, battery level, sensor status, and engine on/off events may be transmitted from the vehicle’s navigation unit or embedded systems as part of your use of the connected services.
3. automatically through the Telenav software: telemetry, usage logs, diagnostics, error reports, network status, and application event data are automatically collected through the software to ensure proper operation and performance of the system.
4. from device and application metadata: system configuration data (e.g., head unit model, OS version, language, region, time zone) and network connectivity details may be accessed to support compatibility, localization, and updates.
5. through inferred or derived data: we may generate statistical or aggregated data about usage patterns, route behavior, or feature interactions by analyzing data collected through the Telenav Software, typically anonymized or pseudonymized before further use;
6. from internal logs and monitoring systems: audit trails, access logs, security incident records, and performance flags may be collected to ensure platform integrity, fulfill legal obligations, or respond to regulatory requests;
7. from public authorities or regulatory bodies (in specific cases): in the context of dispute resolution, investigations, or compliance checks, we may obtain data from or provide data to relevant authorities or regulatory entities, strictly within the boundaries of applicable laws.
8. from the OEM automotive (as a third-party data source): in limited and clearly defined circumstances, Telenav may receive certain pseudonymized or technical data from the OEM. This may include vehicle identifiers, configuration data, or diagnostics logs shared for the following purposes: supporting user support escalations or technical issue resolution; responding to complaints involving navigation system components; fulfilling regulatory inquiries or compliance obligations.

Such data sharing is restricted to what is necessary for the processing purpose in order to provide you with the requested services, and complies with applicable data protection laws and relevant agreements between the OEM and Telenav.

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5. PROCESSING PURPOSES AND LEGAL GROUNDS

We use Personal Data to provide navigation, search services or certain advanced driver assistance features, such as ADAS or Intelligent Speed Assistance (ISA) to you and may also use this information to provide, improve, and enhance our products and services. It may also be shared with the OEM in an aggregated/anonymized format. You may view this Privacy Policy within the navigation system by visiting the "Settings” area.

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1. Service provision and feature enablement

To operate core software features such as described within section I above, the Telenav software requires access to specific system permissions that are critical for its operational performance. Without granting these necessary permissions, navigation services cannot function and the application may not be usable. These permissions may include, but are not limited to:

• geolocation – to obtain your current GPS data for routing, traffic flow information, and nearby POI suggestions;
• storage – to read, modify, and delete files necessary for offline map storage and update caching;
• network – to access network status and maintain a connection to deliver real-time online navigation features.

Categories of data processed: Vehicle Sensor and Status Data, Device and Application Usage Data, Connectivity and Network Information, Inferred or Derived Data, System Configuration and Device Metadata, Localization and Time Zone Data, Telemetry or Sync Events, In-app Diagnostic Flags or Silent Events; Digital Identifiers (Device ID/MAC Address);

Legal basis: contract – processing is necessary for the performance of the End User License Agreement (EULA) between you and Telenav; legitimate Interest – delivering real-time, context-aware navigation features that users expect as part of the connected vehicle experience; ensuring availability and responsiveness across driving environments.

If you don't provide the data or the required permissions: navigation features may not function properly or may be entirely unavailable, reducing the usability, accuracy, and real-time relevance of the system.

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2. Predictive Navigation

To provide predictive route suggestions by analyzing historical navigation patterns, frequent destinations, time of travel, and contextual factors such as traffic or user preferences. This processing may involve profiling, as it builds patterns of user behavior to anticipate likely destinations. Depending on the jurisdiction, explicit consent may be required for this type of processing.

Categories of data processed: Geolocation Data, Navigation History, Time and Frequency of Travel, Destination and Route Preferences, User Profile Settings.

Legal basis: consent (where required by local law) – in jurisdictions that consider predictive navigation as profiling requiring explicit consent, user consent will be requested before activation; legitimate interest – providing a more efficient navigation experience, reducing travel time, and improving route accuracy.

The predictive navigation feature may not be available, and route suggestions will be limited to standard, non-personalized options.

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3. Search Function and Google Search Integration

To enable users to perform searches for destinations, points of interest (POIs), and related services through the integrated search function, which may include Google Search. The feature processes entered search queries together with contextual data (such as location) to deliver relevant and personalized search results.

Categories of data processed: Search Queries (terms entered by the user), Geolocation Data (to contextualize results), User Preferences (such as selected results or filters), Interaction Data (clicks, selections, and engagement with search results).

Legal basis: Contract – processing is necessary to deliver search services as described in the EULA; Legitimate interest – improving the accuracy and relevance of search results, enhancing the overall navigation and search experience, and maintaining system security and service quality; Consent (where required by local law) – for jurisdictions that treat personalization of search results through profiling as requiring explicit user consent, this will be requested before activation.

If you don’t provide the data: The search and Google Search integration features may not work, or results will be less accurate and limited to generic responses without personalization. You can find more details about how Google Search is used and how Google may collect and process data by visiting: https://www.google.com/policies/privacy/. ”

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4. Product improvement and software optimization

To analyze system performance, feature interaction, and usage trends to improve navigation software quality, user experience, and future functionality.
Categories of data processed: Device and Application Usage Data, Inferred or Derived Data, System Configuration and Device Metadata, Telemetry or Sync Events, In-app Diagnostic Flags or Silent Events, Localization and Time Zone Data
Legal basis: legitimate Interest – continuously enhancing product usability, addressing performance issues, and refining features based on real-world usage.
If you don't provide the data: product issues may remain unresolved, and new features may not reflect actual user behavior or needs.

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5. Traffic and road condition analysis

To share anonymized or aggregated navigation data with research and analytics partners to improve traffic intelligence and infrastructure planning.
Categories of data processed: Vehicle Sensor and Status Data, Inferred or Derived Data, Telemetry or Sync Events
Legal basis: legitimate Interest – supporting public interest in traffic safety, road optimization, and environmental efficiency through aggregated insights.
If you don't provide the data: traffic-based improvements may be limited and data-driven features may be less effective.

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6. User support and request handling

To respond to support requests, complaints, or other inquiries submitted by users via available feedback channels.
Categories of data processed: User Support or Feedback Submissions, Data Subject Identity Information, Complaint Submission Data, Email Adress.

Legal basis: contract – processing may be necessary to take steps at your request prior to entering into a contract or for performance of the EULA; legitimate Interest – enabling effective communication and support, resolving user concerns, and ensuring transparency, ensuring proof of transparency; investigating the complaints and resolving the issues; improving Telenav’s services; legal obligation, where it is mandatory to keep/provide the data as per law;
If you don't provide the data: Telenav may not be able to respond to your inquiry or resolve the issue, and some services requiring your identification or consent may not be available.

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7. Legal, tax, and regulatory compliance

To comply with statutory obligations related to data retention, tax, financial documentation, and regulatory audits or legal processes.
Categories of data processed: Data Subject Identity Information, Complaint Submission Data, Investigation and Regulatory Correspondence Data, Legal Retention and Archiving Metadata; any other data from the categories described in this Privacy Policy
Legal basis: legal obligation – compliance with applicable laws (e.g., tax law, audit rules); legitimate interest to keep proof of compliance and select and implement measures and controls to ensure compliance with those legal obligations not defining explicitly the processing operations;
If you don't provide the data: Telenav may be unable to meet its legal requirements and could be restricted from delivering services.

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8. Security monitoring and incident management

To detect, investigate, and respond to actual or suspected security incidents.
Categories of data processed: Security Incident Metadata, Access and Activity Logs (Audit Trails), Authentication and Authorization Data and any other data categories from those described in this Privacy Policy.
Legal basis: legitimate Interest – protecting systems and data, ensuring platform integrity, and preventing misuse or breaches; investigating and solving any security issues; documenting security monitoring and incident management; legal obligations – to implement particular measures, control, solve the incidents in a particular matters; to report to competent authorities and other actors relevant incident related data;
If you don't provide the data: security threats may go undetected, and service continuity or integrity could be compromised.

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9. Consent and preference management

To store and honor user preferences regarding optional data uses and consents.
Categories of data processed: consent and preference records
Legal basis: legal obligation – to ensure compliance with your choices and applicable data protection rules; legitimate interest – to demonstrate compliance with relevant applicable legal rules, to ensure adequate management of permissions, including propagation and withdrawal; 
If you don't provide the data: you may not be able to control or customize how optional data uses apply to you.

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10. Authentication and controlled access

Purpose: to manage user authentication and access permissions for protected tools or portals (e.g., privacy dashboards).
Categories of data processed: Authentication and Authorization data
Legal basis: legitimate Interest – ensuring secure access, preventing unauthorized use, and protecting user-facing services; documenting the implementation of adequate authentication controls; keeping logs, where needed to proof compliance and ensure management of incidents/complaints; to comply with legal obligations requiring particular controls;
If you don't provide the data: you may be unable to securely access tools or manage your privacy preferences.

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11. Internal audits and corporate governance

To conduct internal audits, performance reviews, or risk assessments related to Telenav’s navigation services, in order to ensure internal compliance and operational accountability.
Categories of data processed: Access and Activity Logs (Audit Trails), Legal Retention and Archiving Metadata, Data Subject Identity Information
Legal ground: legitimate Interest – ensuring responsible corporate governance, enforcing internal compliance frameworks, and validating accountability measures, keeping proof of audits; legal obligations, where the law requires particular audits, provision of particular information;
If you don't provide the data: Telenav may be unable to validate its compliance with internal procedures or may face difficulties proving adherence to legal and regulatory expectations.

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12. Probe Data and Data Improvements

To conduct internal research and innovation using anonymized or aggregated data, supporting the future development of technical capabilities or new mobility-related services. This may include contributing to aggregated traffic models and system performance enhancements. 

Categories of data processed: Geolocation Data, Speed, Direction of Travel, Timestamp, System/Device Identifiers (pseudonymized), Inferred or Derived Data, Telemetry or Sync Events, Device and Application Usage Data (anonymized or aggregated)
Legal ground: legitimate Interest – facilitating innovation, supporting the advancement of intelligent mobility solutions, and improving digital infrastructure design; contract – processing may be necessary to deliver core navigation features as described in the EULA.

If you don't provide the data: Telenav may be limited in its ability to explore future-focused service models or contribute to mobility research initiatives.

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13. User Behavior Analytics 

To analyze aggregated and anonymized user interaction data for research and development purposes, in order to enhance service quality, optimize navigation algorithms, and design new features. No decisions are made at an individual level.

Categories of data processed: Aggregated and anonymized usage data, Feature Usage Metrics, Interaction Data (e.g., frequency of feature use, click paths, time spent on functions).

Legal basis: legitimate interest – conducting product research and development, ensuring continual improvement of Telenav’s services, and maintaining competitiveness; or legal obligation – where required to document improvements, audits, or compliance checks.

If you don’t provide the data: The user behavior analytics and continuous improvement functions may be limited, potentially affecting the pace and quality of service improvements, though core navigation services will remain available.

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14. Dispute resolution and legal defense

To establish, exercise, or defend against legal claims in connection with the use of Telenav services or regulatory compliance proceedings.
Categories of data processed: Data Subject Identity Information, Complaint Submission Data, Investigation and Regulatory Correspondence Data, Access and Activity Logs (Audit Trails), Security Incident Metadata
Legal ground: legitimate Interest – protecting Telenav’s legal rights, responding to formal complaints or lawsuits, and ensuring fair handling of disputes.
If you don't provide the data: Telenav may be unable to defend itself effectively in legal proceedings or comply with procedural requirements related to claims or investigations.

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15. Mergers, Acquisitions, and Corporate Transactions

In the event of a merger, acquisition, divestiture, restructuring, reorganization, or sale of all or a portion of Telenav’s assets or business, we may need to transfer or disclose certain personal data to third parties (such as acquiring or merging entities, legal advisors, or auditors) as part of the due diligence process or transaction execution. Any such processing or data sharing will be strictly limited to what is necessary for evaluating or completing the transaction, and will be carried out in accordance with applicable data protection laws, including the principle of confidentiality and purpose limitation.

Categories of data processed: Data Subject Identity Information, System Configuration and Device Metadata, Inferred or Derived Data, Device and Application Usage Data, Contractual and Support Interaction Records, and other data relevant to the transaction scope.

Legal basis: legitimate Interest – ensuring business continuity, enabling corporate development, and allowing the assessment and conclusion of legitimate corporate transactions. Where required, and depending on jurisdiction, additional safeguards (e.g. NDAs, data minimization, pseudonymization) may be applied.

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6. SAFEGUARDING PERSONAL DATA

Your privacy is important to us, and we maintain reasonable, appropriate security procedures to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data. For instance, Telenav limits access to Telenav systems that store such information to authorized personnel. Telenav also uses the Secure Sockets Layer (SSL) protocol to ensure our transmission of Personal Data is secured through encryption.

While Telenav maintains various security measures to prevent unauthorized access to or disclosure of your Personal Data, no security measures are absolute or wholly guaranteed. We recommend you protect yourself against any unauthorized access to your account by keeping your password and log in credentials confidential.

If required by law, we will notify you if it determines unauthorized acts violate the law, this Policy, or other security breaches.

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7. RETENTION OF PERSONAL DATA

Telenav has implemented policies and rules regarding the retention of personal data that fully comply with the Applicable Data Protection Laws. The retention periods are determined as to serve the purposes for which they are collected and processed and are reviewed periodically to meet the standards relating to the limitation of data storage.

The length of time we retain Personal Data, and the criteria we use for determining that time, are dependent on the nature of the Personal Data and the purpose for which it was provided. For example, we retain your Personal Data related to managing your application account (such as name, email address, account content and preferences) for as long as they are retained by you within your account. We may typically maintain other data, such as records of your activity within the application, for a short period before anonymizing such data for further authorized use. We may also retain your Personal Data for other purposes permitted under Applicable Data Protection Laws, including, for example, the defense of any legal claims. We may keep, Personal Data based on what is applicable to the product or service you are using. 

You may contact privacy@telenav.com for additional information about our retention policies regarding your Personal Data.

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8. SHARING OF PERSONAL DATA
   
   1. TELENAV AFFILIATES AND AUTHORIZED THIRD PARTIES

Telenav may share personal data with third parties strictly on a need-to-know basis and only to the extent necessary for the purposes described in this Privacy Policy. All recipients are subject to appropriate contractual and technical safeguards to ensure the protection and confidentiality of your personal data.

We may disclose personal data to the following categories of recipients:

• Telenav affiliates and Group entities
  We may share data within the Telenav group of companies as part of our global operations, subject to our intragroup data protection framework.
• Vendors, partners, and service providers
  We engage third parties who act on our behalf to support the functionality, security, performance, and development of the Telenav Software and related services. These include: companies protecting and securing our systems and services, hosting providers, cloud SaaS software providers (e.g., for diagnostics and technical support), payment processing and billing providers (where applicable), email and communication services providers, security and authentication providers, user support providers, advertising providers, marketing providers, and analytics and measurement services providers (where legally permitted).

All such vendors are contractually required to comply with applicable data protection laws, follow our instructions, and implement adequate safeguards. They are not permitted to use your personal data for their own purposes. Telenav remains liable for any misuse by vendors acting on its behalf, unless it can demonstrate that it is not responsible for the event giving rise to the damage.

• The OEM
  Telenav may share pseudonymized or technical data with the OEM solely for purposes related to vehicle system functionality, diagnostics, customer support, or safety improvements. OEM acts as a separate and independent data controller with its own responsibilities under applicable data protection laws.
• Professional advisors and legal representatives
  Where necessary, we may disclose data to auditors, legal counsel, or consultants for the purposes of legal compliance, dispute resolution, or business continuity planning.
• Public authorities and regulators
  We may disclose data to courts, supervisory authorities, or other competent public bodies where required by applicable law or in response to lawful requests.
• Research and analytics partners
  In anonymized or aggregated form, we may share data with third parties engaged in traffic analytics, system improvement research, or urban mobility studies.

Any vendor or agent that we retain must comply with our data privacy and security requirements and this Policy and are not allowed to use Personal Data they receive from us for any other purpose. We remain responsible and liable under data protection laws if third-party agents we engage to process Personal Data on our behalf do so in a manner inconsistent with the Applicable Data Protection Laws, unless we prove that we are not responsible for the event giving rise to the damage.

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2. MANDATORY DISCLOSURES

We will comply with any subpoenas, court orders or other legal processes for any of the information about you in our possession, and we may use such 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 Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

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9. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Our products and services may be provided using resources and servers in various jurisdictions worldwide. Therefore, we or our partners, vendors or agents may transfer your Personal Data across international borders outside the country where you use our Navigation Services, for example, into the United States of America or Europe. 

In such case, where transfers occur outside EU, in accordance with Articles 44–49 of the General Data Protection Regulation (GDPR), Telenav ensures that all cross-border transfers are protected by adequate safeguards, including:

• Intragroup data sharing agreement
  Telenav has implemented a comprehensive internal data-sharing framework agreement that governs data transfers between Telenav entities located in the EU, US, China, and other jurisdictions. This framework incorporates contractual obligations and technical measures aligned with the Applicable Data Protection Laws’ standards.
• Standard Contractual Clauses (SCCs)
  Telenav adopts the 2021 European Commission–approved SCCs for all transfers to non-EEA countries, ensuring enforceable rights and effective legal remedies for data subjects.
• EU–US Data Privacy Framework (DPF)
  Telenav is a participant in the EU–US Data Privacy Framework, as recognized by Commission Implementing Decision (EU) 2023/1795 of 10 July 2023. This framework provides that certified US organizations, such as Telenav, offer an adequate level of data protection in accordance with EU standards. Telenav is currently completing its re-certification with the U.S. Department of Commerce.

All international data transfers are conducted strictly in compliance with applicable data protection laws, limited to what is necessary for the performance of our services, and supported by appropriate contractual, technical, and organizational safeguards.

In such cases, we ensure that, prior to any transfer, there is a legal basis for such a transfer and that adequate protection for your Personal Data is provided as required by applicable law. 

You may contact the Telenav privacy team at privacy@telenav.com to obtain additional information about the safeguards we take in connection with these transfers.

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10. AUTOMATED DECISION MAKING

To the extent that the fulfillment of some of the above processing purposes will be achieved by using computer techniques that do not involve the presence of a human factor, which will lead to legal effects on you, or which may similarly significantly affect you, as define by the Applicable Data Protection Laws, the processing will be based on your express consent for this purpose or another legal basis, as required by law. In this regard, this document will be updated whenever necessary to ensure that you are properly informed. We do not use such processes at this time. For details on automated decision-making processes, please contact the following address: privacy@telenav.com

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11. YOUR RIGHTS

Depending on your location and the Applicable Data Protection Laws, you may have some or all of the following rights in relation to your personal data. We will respect and honor these rights in accordance with the requirements of the jurisdiction in which you are located.

• Right of Access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and, where that is the case, to access that personal data. This may include details about the purposes of processing, categories of data concerned, recipients of the data, and applicable retention periods.
• Right to Rectification: You have the right to request the correction or completion of inaccurate or incomplete personal data concerning you, without undue delay.
• Right to Erasure (“Right to be Forgotten”): You have the right to request the deletion of your personal data where, for example, the data is no longer necessary for the purposes for which it was collected, you withdraw consent (where consent is the legal basis), you object to processing and there are no overriding legitimate grounds, or the data has been unlawfully processed. We will review your request and, where applicable, delete the data from our active systems and take reasonable steps to inform third parties to whom the data has been disclosed. Please note that exceptions may apply under Applicable Data Protection Laws, such as where processing is required for exercising freedom of expression, compliance with a legal obligation, reasons of public interest, research or statistical purposes, or the establishment, exercise, or defense of legal claims.
• Right to Restrict Processing: You have the right to request the restriction of processing of your personal data in specific circumstances, such as when you contest its accuracy (pending verification), when you object to processing (pending resolution of the objection), when processing is unlawful but you prefer restriction instead of erasure, or when we no longer need the data but you require it for legal claims.
• Right to Object: You have the right to object at any time to the processing of your personal data where such processing is based on legitimate interests. If your objection is justified, we will stop processing. You also have an absolute right to object to processing of your personal data for direct marketing purposes at any time.
• Right to Data Portability: Where permitted under Applicable Data Protection Laws, and where processing is based on consent or contract and carried out by automated means, you may request to receive the personal data you provided to us in a structured, commonly used, and machine-readable format, and to have that data transmitted to another controller where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing carried out before your withdrawal or processing based on other lawful grounds. Withdrawal of consent may limit our ability to provide certain services.
• Right Not to Be Subject to Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects on you, unless such processing is required by law, necessary for a contract, or based on your explicit consent.
• Right to Lodge a Complaint: You may lodge a complaint with the competent supervisory authority if you believe that your personal data is being processed in violation of Applicable Data Protection Laws.
• Right to Know / Right to Disclosure: You have the right to request information about the categories and specific pieces of personal data we collect, the sources of that data, the purposes for which we use it, and the categories of third parties with whom we share it.

• Right to Opt-Out of Sale or Sharing of Personal Data: You may request that we do not “sell” or “share” your personal information as defined under certain state privacy laws (for example, California). This includes opting out of data sharing for cross-context behavioral advertising.

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Please note that the applicability of these rights may vary depending on the nature of the processing activity, the legal basis relied upon, and the Applicable Data Protection Laws in your jurisdiction. In some cases, we may request verification of your identity before acting on your request. Where requests are manifestly unfounded or excessive, in particular due to their repetitive character, we reserve the right to charge a reasonable administrative fee or to refuse to act on the request, as permitted by the Applicable Data Protection Laws.

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12. CONTACTING TELENAV

For questions related to protecting personal data, exercising your rights, or registering a complaint, contact Telenav’s data protection officer by e-mail or postal at the address specified below:

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Telenav Shanghai Inc

Attention: DPO

27F & 28B V-Capital No. 333,

Xian Xia Road, Shanghai, China
Phone +86 21 32522288

Email: privacy@telenav.com

Telenav, Inc
Attention: DPO
2540 Mission College Boulevard, Suite 100

Santa Clara, CA 95054

Phone 408 245 3800

Email: privacy@telenav.com

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With respect to any notice or request you may provide under this Policy, we will verify your identity or the identity of your authorized agent submitting the request on your behalf, and we will then comply with your request. We will verify your identity either to a "reasonable degree of certainty" or a "reasonably high degree of certainty" depending on the sensitivity of the Personal Data and the risk of harm to you by unauthorized disclosure or deletion as applicable. We may require you to provide additional personal data to verify your identity before we can process your request.

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13. ABOUT THIS POLICY

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 Policy conflicts with any provision of those terms and agreements, those terms and agreements govern to the extent of the inconsistency. In all other instances, the terms of this Policy apply.

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GOVERNING LAW

By choosing to use our Telenav Platform or otherwise provide information to Telenav, you agree that any dispute over privacy or the terms contained in this Policy will be governed by the laws of the State of California, United States of America; provided, however, (i) this Policy shall be governed by the Applicable Data Protection Laws or (ii) such other governing law as may be mandated by the jurisdiction in which you reside. 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.

Telenav is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

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CHANGES TO THIS POLICY

We may update this Policy according to changes in our business functions, measures concerning the protection of Personal Data and Applicable Data Protection Laws. If we make changes to this Policy, we will notify you through the Navigation APP in vehicle. Where changes to this Policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you may have. 

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