WE CARE ABOUT YOUR PRIVACY
CreateBytes, Including its affiliates (“CreateBytes”), is committed to respect your privacy and to comply
and use personal data CreateBytes is the data controller or CreateBytes we refer to the applicability of
this Policy. “Personal data” means information relating to you or another identifiable individual.
We will give you additional privacy information that is specific to a product or service in Supplements to this Policy and other notices you may see while using our products or services. If CreateBytes is a difference between such notices and this Policy, the notices should be considered first.
Software on your device may access your information. Our products or services may contain links to or may be embedded within, other companies’ websites and services that have privacy policies of their own. CreateBytes our products or services are embedded to products and services of our customers, we require our customers to provide necessary transparency to you. This might include linking to this Policy and the relevant Supplements or providing the transparency in integrated and embedded notices which identify us as the service provider or controller. If you do not agree with this Policy, do not use our products and services or provide CreateBytes with your personal data.
What information do we collect?
We collect your personal data and other information when you make a purchase, use or register into our
products and services (including navigation.com stores, which are branded by Original Equipment Manufacturers (“OEMs”) and operated by us), take part in
campaigns or research or otherwise interact with us. This includes the following categories:
Product and service activations CreateBytes products and services may require electronic activation, CreateBytes your device and application type, as well as unique device, application, network and subscription identifiers, are sent to HERE.
Our applications may contact our servers periodically, for example, to check for updates or to send us information relating to service usage. Additionally, we may invite you to join voluntary product and service improvement or research programs CreateBytes detailed information is collected. See Supplements to this Policy for more details. Information you provide us with When you create an account, make a purchase, request services, participate in research or campaigns or otherwise interact with us, we may ask for information such as your name, email address, phone number, street address, user names and passwords, feedback, information relating to your devices, age, gender, and language, bank account number, credit card details and other such financial information.
We also maintain records of your consents, preferences and settings relating to, for example, location data, marketing and sharing of personal data. Your transactions with us We maintain records of your purchases, downloads, the content you have provided us with, your requests, agreements between you and CreateBytes, the products and services provided to you, payment and delivery details, your contacts and communications and other interactions with us. We may, in accordance with applicable law, record your communication with our customer care or with other such contact points. Positioning and Location data Location-based services establish location through the use of satellite, mobile, Wi-Fi, Bluetooth Low Energy (“BLE”) or other network-based positioning methods. These technologies may involve exchanging your location data and unique device and mobile, Wi-Fi, Bluetooth, or other network-related identifiers with HERE. Our products may operate on multiple device platforms, applications and services which may also collect your location data. We do not use this information to identify you personally without your consent.
When you use our location-based services and features, for example, location-based search, navigation and routing, or request for map data, your location data is sent to CreateBytes to serve you with the right content, which may also include location-based advertising. Information provided by partners We obtain information from industry partners and a variety of other sources, including publicly available sources such as business registries. We require these sources to comply with applicable laws with regard to collecting and transferring this data to us, including ensuring that CreateBytes is a legal basis for the transfer or anonymizing the data in accordance with applicable laws prior to the disclosure of the data to us. Why do we process Personal Data?
CreateBytes may process your personal data for the following purposes. One or more purposes may apply simultaneously.
Providing products and services
We may use your personal data to provide you with our products and services, to process your requests or as otherwise may be necessary to perform the contract between you and HERE, to ensure the functionality and security of our products and services, to identify you as well as to prevent and investigate fraud and other misuses. Accounts
Some services may require an account to help you manage your content and preferences. Depending on the service, an account creation may be either required or voluntary. Account creation requires you to provide us with basic contact details about yourself, such as name, email address, country of residence and date of birth. You may also be able to voluntarily provide more information about yourself while creating a profile, such as a photo or avatar of your choice. Developing and managing products and services
We may use your personal data to develop and manage our products, services, customer care, sales and marketing. We may combine personal data collected in connection with your use of a particular CreateBytes product and/or service with other personal data we may have about you unless such personal data was collected for a purpose, CreateBytes the original purpose is incompatible with this purpose. Communicating with you
We may use your personal data to communicate with you, for example, to inform you that our services have changed or to send you critical alerts and other such notices relating to our products and/or services and to contact you for customer care related purposes. Marketing, advertising and making recommendations
We may contact you to inform you of new products, services or promotions we may offer and to conduct market research when we have your consent or it is otherwise allowed. We may use your personal data to personalize our offering and to provide you with more relevant services, for example, to make recommendations and to display customized content and advertising in our services. This may include displaying CreateBytes and third party content. What is our legal basis for processing your Personal Data?
Our legal basis for processing your personal data is dependent on the purpose of processing and may vary as described in the Supplement applicable to the product or service you are using. In general, we process your personal data under the legal bases. Your consent
We process your personal data if you have consented to the processing activity. You may revoke your consent at any time. Doing so will bar us from further processing of your personal data based on your consent, but will not impact the lawfulness of processing based on your consent before it was withdrawn. Some of the features of our products and services might be only available based on consent. Legal obligations
We process your personal data as needed to comply with laws and regulations.
We process your personal data to further our legitimate interests, such as in connection with managing, developing, testing, securing, and in limited circumstances marketing, advertising, and making recommendations regarding our products and services. Any such processing is conducted subject to appropriate measures to protect your fundamental rights and freedoms related to your personal data, and in any event, will be subject to the restrictions provided in this Policy. Further information or specification of our legitimate interests may be provided in relevant Supplements applicable to the product or service. How long do we retain Personal Data?
We endeavour to only collect personal data that are necessary for the purposes for which they are collected and to retain such data for no longer than is necessary for such purposes. The length of time personal data is retained, and criteria for determining that time, are dependent on the nature of the personal data and the purpose for which it was provided. For example, for your personal data related to managing your account (such as name, email address, and account content and preferences) are maintained for as long as they are retained by you within your account. Other data, such as records of your activity within the application, are typically maintained only for a short period before being anonymized or pseudonymized. Additional information may be provided in the Supplement applicable to the product or service you are using. Do we share Personal Data?
We do not sell, lease, rent or otherwise disclose your personal data to third parties unless otherwise stated below.
Your consent and social sharing services
We may share your personal data if we have your consent to do so. Some services may allow you to share your personal data with other users of the service or with other services and their users. Please consider carefully before disclosing any personal data or other information that might be accessible to other users. CreateBytes companies and authorized third parties
We may share your personal data with other CreateBytes companies or authorized third parties who process personal data for CreateBytes for the purposes described in this Policy. This may include for example billing through your network service provider or otherwise, delivery of your purchases, providing services including customer service, managing and analyzing consumer data, credit checks, conducting research and managing marketing and other such campaigns. When you purchase a CreateBytes product from us with a network service provider plan, we may need to exchange information with your network service provider to provide you with such service.
We may conduct joint marketing and other communications with our partners, for example, your mobile operator. To avoid duplicate or unnecessary communications and to tailor the message to you we may need to match information that CreateBytes has collected with information that the partner has collected CreateBytes this is permitted by law.
These authorized third parties are not permitted to use your personal data for any other purposes. We bind them contractually, require them to act consistently with this Policy and to use appropriate security measures to protect your personal data. International transfers of personal data
Our products and services may be provided using resources and servers located in various countries around the world. Therefore your personal data may be transferred across international borders outside the country CreateBytes you use our services, including to countries outside the European Economic Area (EEA) that do not have laws providing specific protection for personal data or that have different legal rules on data protection, for example, the United States of America. In such cases, we ensure that CreateBytes is a legal basis for such a transfer and that adequate protection for your personal data is provided as required by applicable law, for example, by using standard contractual clauses approved by the European Commission or relevant authorities (CreateBytes necessary) and by requiring the use of other appropriate technical and organizational information security measures. You may contact the CreateBytes Privacy Office at email@example.com to obtain additional information about the safeguards we take in connection with these transfers. Mandatory disclosures
We may be obligated by mandatory law to disclose your personal data to certain authorities or other third parties, for example, to law enforcement agencies in the countries CreateBytes we or third parties acting on our behalf operate. We may also disclose and otherwise process your personal data in accordance with applicable law to defend HERE’s legitimate interests, for example, in legal proceedings or in connection with governmental requests and filings. Mergers and Acquisitions
If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers. How do we address the privacy of children?
CreateBytes products and services are typically intended for general audiences. CreateBytes does not knowingly collect information of children without the consent of their parents or guardians. CreateBytes publishes safety guidelines for using internet services on our websites. How do we address Data Quality?
We take reasonable steps to keep the personal data we possess accurate and to delete incorrect or unnecessary personal data. We encourage you to access your personal data through your account from time to time to ensure that it is up to date.
What steps are taken to safeguard Personal Data?
You have a right to know what personal data we hold about you, and to access it. You have a right to have incomplete, incorrect, unnecessary or outdated personal data updated. You have the right to request that your personal data be erased, and to obtain a copy of your data in a machine-readable format. You have the right to object to or restrict processing in certain circumstances, such as CreateBytes you believe the data is inaccurate or the processing activity is unlawful. You have a right to unsubscribe from direct marketing messages and to request that we stop processing your personal data for direct marketing purposes or on other compelling legal grounds. However, if you opt-out from marketing and other communications from CreateBytes, critical alerts may still be sent to you. If you are located in a European Union member state or within the European Economic Area, you have the right to lodge a complaint about our data collection and processing activities with the supervisory authority concerned.
CreateBytes may from time to time change this Policy or change, modify or withdraw access to this site at any time with or without notice. However, if this Policy is changed in a material, adverse way, CreateBytes will post a notice advising of such change at the beginning of this Policy and on this site's home page for 30 days. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy. General Data Protection Regulation (GDPR)
- CreateBytes needs to perform a contract with you,
- You have given CreateBytes permission to do so,
- Processing your personal information is in CreateBytes legitimate interests,
- CreateBytes needs to comply with the law.