Summary of the Privacy Policy

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

Privacy Policy

This Privacy Policy (hereinafter referred to as the „Policy”) has been published on and is effective as of 25th February, 2021.

1. DEFINITIONS

   Application CID identifies the exact navigation software version by device model, per region, per device variant.

   Content means maps, points of interest, 3D content, voices, language files, and other navigation-related content, which can be uploaded on your Navigation Device and used with your Software.

   Device means You are using for browsing, registration or interacting with the newsletter (laptop, desktop, tablet, mobile or any other electronic device).

   FCA Toolbox means a free software tool for PC and MacOS, which is used to download Updates and Products from NNG’s servers and upload them to the Navigation Device.

   Free Product means the Updates, Content and Connected Services to which the User is entitled to free of charge during the Mapcare Period.

   GDPR means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

   Mapcare Period means the period while Free Product is available and provided for the User (usually it is a three-year period).

   Navigation Device means the in-car navigation system built into your vehicle (including the SD card/USB stick, or other data carrier that contains the navigation data).

   NNG means NNG Software Developing and Commercial Limited Liability Company

   Registered office:	Szépvölgyi út 35-37., H-1037 Budapest, Hungary
   Court of registration:	Budapest-Capital Regional Court (Fővárosi Törvényszék)
   Company registration number:	01-09-891838
   Tax number:	13357845-2-44
   Email address:	privacy@nng.com

   Partner means FCA US LLC (1000 Chrysler Drive, Auburn Hills, MI 48326 USA).

   Product means Updates, Content.

   Profiling means automated processing of personal data, as listed in point 2.4.2.2 in order to provide the User with personalized newsletters relevant for the User and for his/her registered Navigation Device(s) in order to increase user experience and satisfaction.

   Site means https://fca-mapupdate.welcome.naviextras.com and its subdomains.

   Software means the navigation software that runs on your Navigation Device.

   Updates mean Content and Software updates, which are provided by your Navigation Device manufacturer or Software developer, and which provide additional features, new Content versions, or fix known Software problems.

   User or You means a registered user of the Site and/or the FCA Toolbox.

   User Activity means location and behaviour data (language selection in the FCA Toolbox/on the Site, products put in the User’s cart), onsite browsing history, usage patterns (frequency/patterns of logging-in to investigate fraud, misuse of the FCA Toolbox/Site).

   VIN (Vehicle Identification Number) means the unique serial number of the vehicle.

2. PRIVACY POLICY

   1. Purpose of this document

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

   2. Availability and updating of this document

      NNG reserves the right to amend this document unilaterally at any time. We suggest visiting the Site and FCA Toolbox from time to time for the latest information, however, You will also be informed of this Policy being amended in case of significant changes (e.g. legal basis of processing, scope of processed data, person of data processor) of the Policy.

   3. Data controller

      1. The data provided in the FCA Toolbox is processed by NNG.

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

         • NNG’s employees and managers involved in the data collection;
         • IT specialists performing a variety of IT tasks related to the operation and maintenance of NNG’s computer system as part of their role within NNG in connection with performing their duties associated with the purpose of this Policy.

   4. Data processing

      1. Processing of data provided by the User during the registration in the FCA Toolbox

         1. Purpose of data processing

            1. Administering registration in the FCA Toolbox and User account maintenance.

               If the User wishes to download or redeem a prepaid code for a Product, he/she shall download the FCA Toolbox through the link available on the Site and register in the FCA Toolbox. User account maintenance includes but is not limited to the performance of NNG’s duties in connection with your rights specified in section 2.7.

            2. Provision of Updates

               The process of carrying out an Update is the following: the User shall synchronize the data of the Navigation Device to a USB flash drive manually. The USB flash drive in this way will contain all information which is necessary to carry out an Update. The User shall insert the USB flash drive to the PC and launch the FCA Toolbox application. By using the FCA Toolbox application, information listed in section 2.4.1.2 b) is sent from the FCA Toolbox to the NNG server.

            3. Sending system notifications

               NNG sends system notifications in connection with technical issues in relation to and during the access to Products, including, but not limited to technical issues during downloading the Content, notification related to Updates during Mapcare Period, notification related to Mapcare expiration date, to release of a new FCA Toolbox, and changes in the privacy policy.

         2. Scope of the User’s processed personal data provided during the registration in and/or usage of the FCA Toolbox:

            1. The following information is processed related to the registration of the User:
               
               
               • User’s name;
               • User’s email address;
               • Country;
               • User Activity,
               • Encrypted, non-deciphered password.
            2. The following information is processed related to the recognition of Navigation Device:
               
               
               • brand and model to identify the Navigation Device;
               • SWID (an ID created from the VIN using a one-way hash function);
               • First login date in FCA Toolbox;
               • Software version;
               • first use date (the time of the first GPS fix of the navigation head unit);
               • VIN;
               • Application CID.

         3. Legal basis of data processing

            The data is processed in compliance with GDPR and all relevant local laws.

            The legal basis of data processing is the performance of contract pursuant to point b) of Article 6(1) of the GDPR. During the Mapcare Period or by redeeming a prepaid code purchased from your dealer NNG is providing (Free) Products to You as subcontractor of the Partner and processing your data in order You can access and download the (Free) Products during the Mapcare Period, or to which you are entitled to based on the redeemed prepaid code. NNG is processing your data in order to perform said contract and administer your account, such as your Navigation Device history.

         4. Duration of data processing

            Your personal data uploaded via the FCA Toolbox is retained for the period during which any Update or Product is available and supported by NNG, or until You cancel your account.

            Notwithstanding the above, NNG shall immediately delete your personal data if You specifically request the deletion thereof and there is no valid legal ground for data processing.

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

         1. Purpose of data processing

            The User can subscribe to NNG’s newsletter on the Site and/or in the FCA Toolbox by ticking the appropriate checkbox.

            NNG sends newsletters to inform the User about new Products (e.g. updates to Content are available) and promotions, or other marketing activities. In order to provide You with personalized newsletters relevant for You and your registered Navigation Device(s) and increase your user experience and satisfaction NNG uses Profiling techniques with the involvement of salesforce.com EMEA Limited, as data processor, to receive information of your Device and the geographical region your Device is located.

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

         2. Scope of the processed personal data of the User

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

            Data processed for Profiling purposes:

            • User’s interaction with the delivered email (i.e. whether the email was opened, how many times the addressee clicked on it, whether the addressee read the entire email);
            • Bounce rate of the newsletters sent to the User;
            • OS and OS version of Device;
            • type and version of email client of User;
            • type of Device (including manufacturer of the Device, whether the Device qualifies as phone or not, screen resolution)
            • IP address and geolocation data (i.e. country/region information).

         3. Legal basis of data processing

            The data is processed in compliance with GDPR and all relevant local laws.

            The legal basis of data processing is

            • the User’s express consent given pursuant to point a) in Article 6(1) of the GDPR and
            • sections 6(1) and (2) of Act XLVIII of 2008 on the basic requirements of and certain restrictions on commercial advertising activities (“Advertising Act”).

         4. Duration of data processing and subscription to newsletters

            1. Your personal data uploaded via the Site and/or the FCA Toolbox is retained for the period during which the Update is available, and your Navigation Device is supported by NNG, or until You unsubscribe from the newsletter.

            2. The User may withdraw his/her consent at any time as follows:

               • By following the instructions in the newsletter. Click on the unsubscribe link at the bottom of the newsletter.
               • By logging in to your User account via the FCA Toolbox where You can deactivate the appropriate checkbox.
               • By sending a request to NNG through https://nng.force.com/naviextrasknowledgebase/s/support.
               • By sending a mail to NNG’s postal address (the registered office) specified in section 1.

            3. Please note that unsubscribing from the newsletter does not affect the lawfulness of data processing based on your consent and conducted before such withdrawal and unsubscribing from newsletter is not equal with cancelling your account (see section 2.7.6). Please note that system notifications sent under section 2.4.1.1 c. are not equal with newsletters, so unsubscribing from newsletters does not affect the lawfulness of sending system notifications.

   5. Data processor

      1. Data processing related to enforcing the User’s rights specified in section 2.7

         In order You can enforce your rights as a data subject specified in section 2.7 NNG cooperates with the following data processors:

         1. Salesforce.com

            Name:	salesforce.com EMEA Limited
            Address:	Floor 26 Salesforce Tower, 110 Bishopsgate EC2N 4AY London, UK
            Website:	https://www.salesforce.com/
            Contact information:	https://www.salesforce.com/form/contact/contact-privacy.jsp

            Salesforce.com provides NNG with an online system through which NNG can manage receipt of your requests sent through the online form specified in section 2.7.2 i regarding enforcing your rights as a data subject and sending answers to your request.

         2. United Call Centers

            Name:	UNITED CALL CENTERS Tanácsadó Kereskedelmi és Szolgáltató Kft.
            Address:	Kis-Hunyad utca 9. II floor, H-3525 Miskolc, Hungary
            Website:	https://unitedcallcenters.hu/
            Contact information:	https://unitedcallcenters.hu/#project-footer

            United Call Centers provides multilingual 1st level customer care and technical support service to NNG’s end-users via e-mail, chat and telephone.

            United Call Centers has access to those personal data which were given by Users during the registration via the Site/FCA Toolbox (e.g. name, e-mail address, country) and/or which were generated automatically during the Updates and during the communication between the User and NNG in the system provided by Salesforce.com related to the enforcement of the data subject’s rights.

            United Call Centers does not store any personal data of the User on its own servers.

      2. Data processing related to the sending of newsletters

         1. For sending newsletters to the Users, NNG cooperates with Salesforce.com as data processor, which provides email marketing services.

            Name:	salesforce.com EMEA Limited
            Address:	Floor 26 Salesforce Tower, 110 Bishopsgate EC2N 4AY London, UK
            Website:	https://www.salesforce.com
            Contact information:	https://www.salesforce.com/form/contact/contact-privacy.jsp

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

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

            • Storing the User’s personal data;
            • Sending emails to the User;
            • Analysing the User’s interaction with the delivered email (in particular whether the email was opened, how many times the addressee clicked on it, whether the addressee read the entire email);
            • Analysing the bounce rate (e.g. cases in which the email address is invalid or the email is listed as spam)
            • Collecting data of User’s registered Device and its geolocation (OS and OS version of Device; type and version of email client of User; type of Device (including manufacturer of the Device, whether the Device qualifies as phone or not, screen resolution); IP address and geolocation data (i.e. country/region information)).

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

      3. Data processing related to providing the User with the Updates

         1. In order NNG can provide You with the Updates, NNG uses cloud computing services provided by Microsoft Azure.

            Name:	Microsoft Ireland Operations, Ltd.
            Address:	Carmenhall Road Sandyford, Dublin 18, Ireland
            Website:	https://azure.microsoft.com/hu-hu/
            Contact information:	https://azure.microsoft.com/hu-hu/overview/sales-number/

            Microsoft has access to all personal data of the Users listed in the present Policy.

   6. Data security

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

   7. Rights and remedies

      1. Any personal information which You provide for NNG must be true, complete, and accurate in all respects. You can modify your personal data at any time by logging in to your User account through the FCA Toolbox.

      2. You are entitled to exercise the following rights in relation to NNG's data processing activities:

         • Request information on the processing of your personal data (see section 2.7.3);
         • Request data portability (2.7.4).
         • Request the rectification of your personal data (see section 2.7.5);
         • Request the deletion of your personal data or restriction of the processing of your personal data (see section 2.7.6 and 2.7.7);
         • Object to NNG's data processing (see section 2.7.8).

         In the event You wish to exercise any of your rights detailed above, please send your request by using one of the following means:

         1. By sending a request to NNG through https://nng.force.com/naviextrasknowledgebase/s/support.

         2. By sending an email to NNG’s email address specified in section 1.

         3. By sending a mail to NNG’s postal address (the registered office) specified in section 1.

      3. You are entitled to request information on data related to You and processing carried out by NNG thereof, especially information as to what personal data relating to You is stored; the sources from which they were obtained; the purpose, grounds, and duration of processing; if your personal data is made available to others, the legal basis and the recipients; and any data protection incident in relation to your personal data. NNG shall provide written information on the processing of your personal data within 1 months after receipt of the request. You may also request the correction of your personal data.

      4. You are also entitled to request a structured, commonly used and machine-readable formatted copy of your personal data that NNG is processing subject to conditions set out in Article 20 of the GDPR.

         You have the right to transmit your personal data to another controller or, where it is technically feasible, You can request NNG to transfer your personal data directly to another controller as specified in Article 20 of the GDPR.

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

      6. Your personal data shall be deleted upon your request in accordance with applicable laws. NNG shall delete all stored personal data in compliance with this Policy by obfuscating your personal data, by making it anonym in a permanent and non-reversible manner.

         Please be informed that your data will not be deleted if the processing thereof is required by law or other exceptions apply under applicable law.

      7. You have the right to obtain restriction of processing from NNG in the following cases:

         1. You think that your processed personal data is not accurate, for a period enabling NNG to verify the accuracy of your personal data;

         2. the processing is unlawful, and You opposes the erasure of your personal data, You are entitled to request restriction of their use instead;

         3. NNG no longer needs your personal data for the purposes of processing, but You require NNG to continue the processing for the establishment, exercise or defence of your legal claims;

         4. You have objected to processing, for a period pending the verification whether the legitimate grounds of NNG override those of yours.

      8. At any time, You have the right to object to processing your personal data subject to certain conditions under applicable laws, You may separately object against processing your personal data for direct marketing purposes, including Profiling, as set out herein. In this case, NNG will no longer process your personal data unless if NNG demonstrates compelling legitimate grounds for the processing which override your interests, rights and data protection related freedoms or if the processing is necessary for the establishment, exercise or defence of legal claims.

      9. You may lodge a complaint about the processing of your personal data to the National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság – “NAIH”; address: 1055 Budapest, Falk Miksa utca 9-11..; postal address: 1363 Budapest, Pf.: 9.; phone: +36-1-391-1400; facsimile: +36-1-391-1410; email: ugyfelszolgalat@naih.hu) or to the data protection authority of your home country or country of your residency.

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

      11. Your detailed rights and remedies are set out in Articles 15-21 of the GDPR.

   8. Contacting NNG

      We value your opinion. If You have any comments, questions, or wish to obtain more information on data processing at NNG, please send your request as specified in section 2.7.2. We will handle the submitted information confidentially. Our representative will contact You within a reasonable time.

      The data protection officer (DPO) of NNG can be contacted under DPO@nng.com email address. The DPO at the time of publishing of this Policy is Adrienn Micskei, however, even in case the person of the DPO may change he/she will be continuously available to contact under DPO@nng.com email address.