HOW WE USE YOUR DATA
Our Principles
TomTom is all about where you are and getting to where you want to be. We help you achieve more. So
we can help you, sometimes we’ll need to know some things about you. While we collect and use your
data, we fully understand that you value your privacy.
We believe privacy is about freedom and being able to decide for yourself how your data is used and
by whom. This is why we have established our Privacy Principles:
1. We will always keep you fully informed about your data
We make sure you understand which data from or about you we use, why we use it, how long we use it
and
who can use it.
2. We enable you to remain in control of your data
We consider the data from or about you to be yours. We only use it for the purposes for which you
have given it to us, or for which we collected it from you. At any time you can opt-out or opt-in
using our software and websites.
3. We protect your data
Your data is yours. We keep it that way by protecting it as best as we reasonably can to prevent it
from falling into the wrong hands.
Our ten promises to you
1. We will tell you which data from or about you we use, why we use it, how long we use it, who else can use it and where it is kept.
2. We will only use your data for the purposes we have stated to you.
3. We keep as little of your data as possible, and only for as long as we need it. When we no longer need data we destroy it or we irreversibly anonymise it, so it is no longer linked to you.
4. If we ask your permission to use your data for specific purposes, we also allow you to withdraw your permission.
5. If we have not been able to ask your permission to collect and use your data and you don’t want us to do so, you can tell us and we will act accordingly.
6. We will allow you to access and correct your data if it is linked to your MyTomTom account.
7. We will keep protecting your data against unauthorized access and accidental loss as best as we reasonably can.
8. If we engage others to use your information on our behalf, we will ensure they act in accordance with our policies.
9. If we share your data with others, we will first ask you for permission, unless there is a legal obligation that prohibits us from asking.
10. We are open to any questions you may have about how we use your data and we will answer them.
TomTom policy on privacy and processing of personal data
We operate according to the privacy laws applicable in your country. Because we are rooted in Europe,
European privacy laws also apply. These laws are considered to be the most extensive in the world.
They offer a high level of protection to you by only allowing us to use your data when the strict
conditions of these laws are met. Our company policy on privacy and processing of personal data
reflects these laws and we apply this policy globally.
Definitions
Personal Data: any information relating to an identified or identifiable natural person (‘Data
subject’, user); an identifiable person is one who can be identified, directly or indirectly, in
particular by reference to an identification number or to one or more factors specific to his
physical, physiological, mental, economic, cultural or social identity;
Processing of Personal Data ‘processing’: any operation or set of operations which is performed upon
Personal Data, such as collection, recording, organization, storage, adaptation or alteration,
retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making
available, alignment or combination, blocking, erasure or destruction.
- TomTom will process Personal Data fairly and lawfully.
- TomTom will collect Personal Data for specified, explicit and legitimate purposes and will not
further process Personal Data in a way incompatible with those purposes.
- TomTom will ensure Personal Data is adequate, relevant and not excessive in relation to the
purposes for which they are collected and/or further processed.
- TomTom will ensure Personal Data are accurate and, where necessary, kept up to date.
- TomTom will keep Personal Data in a form which permits identification of its users for no longer
than is necessary for the purposes for which the Personal Data were collected or for which they
are further processed.
- TomTom will process Personal Data only if:
a) the user has unambiguously given his consent; or
b) processing is necessary for the performance of a contract to which the user is party or in
order to take steps at the request of the user prior to entering into a contract; or
c) processing is necessary for compliance with a legal obligation to which TomTom is subject; or
d) processing is necessary for the purposes of the legitimate interests pursued TomTom, except
where such interests are overridden by the interests for fundamental rights and freedoms of the
user and in particular his right to privacy.
- TomTom will avoid processing Personal Data revealing racial or ethnic origin, political
opinions, religious or philosophical beliefs, trade-union membership, or Personal Data
concerning health or sex life.
- TomTom will avoid processing Personal Data related to persons under the age of 13 years.
- To ensure fair processing of Personal Data, TomTom will inform its users of
a) The purposes of the processing;
b) The categories of the Personal Data concerned;
c) The categories of the recipients of the Personal Data;
d) How to access and rectify their Personal Data.
- TomTom implements appropriate technical and organizational measures to protect Personal Data
against accidental or unlawful destruction or accidental loss, alteration, unauthorized
disclosure or access, in particular where the processing involves the transmission of Personal
Data over a network, and against all other unlawful forms of processing. TomTom does so having
regard to the state of the art and the cost of their implementation, ensuring a level of
security appropriate to the risks represented by the processing and the nature of the Personal
Data to be protected.
- In case processing is carried out on TomTom’s behalf, TomTom will choose a processor providing
sufficient guarantees in respect of the technical security measures and organizational measures
governing the processing to be carried out, and will ensure compliance with those measure. In
these cases TomTom will ensure the processing is governed by a contract binding the processor to
the controller and stipulating in particular that:
a) The processor shall act only on instructions from TomTom;
b) The provisions of 10) are applied to the processor.
- In principle TomTom will process Personal Data in the European Economic Area (EEA). In those
cases where Personal Data is transferred or processed outside the EEA by TomTom or on TomTom’s
behalf, TomTom will ensure adequate safeguards with respect to the protection of the privacy and
fundamental rights and freedoms of individuals and as regards the exercise of the corresponding
rights by applying appropriate contractual clauses or other acceptable legally binding
instruments.
- In case TomTom remotely stores information, or gains access to (any) data already stored, in a
device of a user, TomTom will ensure the user concerned has given his or her consent, having
been provided with clear and comprehensive information, about the purposes of the processing.
This shall not prevent TomTom from any technical storage or access for the sole purpose of
carrying out the transmission of a communication over an electronic communications network, or
as strictly necessary in order for TomTom to provide a service explicitly requested by the user.
Data we collect
When you use our sites, our products and our services we collect data from you or about you. What
data we exactly collect depends on what you use and how you use it. In general there are 3
categories of data we collect and use:
Data you provide
This is the data you enter yourself when using our sites, products and services. This data includes
for example your name, email address, the search terms you enter, your address and favourite
locations, your phone number, any map errors reports and speed camera reports you enter, your size,
weight, gender, age etc. etc.
Data collected via sensors
A lot of our products come equipped with one or more sensors or use the sensors of the devices they
run on. Examples of sensors are GPS receivers, WiFi or Bluetooth receivers, a camera, a microphone,
G-force sensors, hart rate sensors and touch sensitive screens. These sensors, when activated, will
automatically collect data. Depending on the purpose for which it was captured, the data in
combination with data that identifies you or your device can be sent to TomTom and others for
subsequent use.
Metadata
This refers to any data that is collected or automatically generated while you use TomTom sites,
products or services. In many cases metadata is collected or generated inherent to you using a
computing device or inherent to transmitting data over computer networks, such as the internet. This
data includes user interface and other device usage events, IP-addresses, unique device identifiers,
WiFi and Bluetooth MAC addresses, cookies and records of computer activity.
Data we receive from others
We receive data from third parties that they have collected, under their responsibility and in
accordance with their privacy policy, and shared with us. We use that data within the limits of what
these third parties allow us to do with it while also adhering to our own privacy principles and
policy. We receive real-time feeds of location, speed, sensors and other vehicle and device
information from, for example, mobile phone users, business fleets and vehicles that are equipped
with our on-line maps or traffic and travel services. We use this data only after we have made sure
it cannot be linked back to you.
We also receive data from others about you when you have interacted with them, for example when you
have visited their websites or used their mobile apps. This data can include IP-addresses, unique
device identifiers, advertising identifiers, Wi-Fi and Bluetooth MAC addresses, cookies and other
records of computer activity, as well as indications of your behaviour, interests and demographic.
MyTomTom account
TomTom uses your MyTomTom account to grant you access to downloadable content, services you are
subscribed to or have activated, software upgrades and sections of our website which need registration.
We also use your MyTomTom account when you want to purchase additional items and to tailor our offerings
to you. The way in which TomTom uses your MyTomTom account also depends on the software and device or
system you use.
To create your MyTomTom account, as a minimum you need to supply your name and email address and choose
a password. TomTom advises you to keep your MyTomTom account details confidential and use a password you
do not use elsewhere.
We will use your email address occasionally to send information related to the products and services
registered to your MyTomTom account. We will only do this if there are updates you need to be aware of
to ensure you can use your product in a safe, reliable way, without interruption or if there is a legal
requirement to contact you.
Using your MyTomTom account, you can also subscribe to the TomTom News email, which provides the latest
news, product information and special offers from TomTom and others we select. You can opt-out of
receiving the TomTom News email at any time by clicking on the appropriate link in the emails you
receive.
Should you wish to delete your MyTomTom account, please visit tomtom.com/support.
We will not share your MyTomTom account details with anyone else, unless they work under our
responsibility, according to our instructions or when explicitly and lawfully ordered to do so following
due legal process.
Service management and improvement
TomTom keeps information that tells us how and when you use our services. This includes information
about the device you are using and the information we receive while you use the service, such as
locations, routes, destinations and search queries. TomTom uses the information for technical
diagnostics, to detect fraud and abuse, to create usage reports, and to improve its services. The
information is kept only for these purposes and for a limited period of time, after which it is
destroyed. TomTom is unable to identify you based on this information, and will not try to. TomTom
applies security methods based on industry standards to protect the information against unauthorised
access. TomTom will not give anyone else access to the information or use it for any other purpose,
unless explicitly and lawfully ordered to do so following due legal process.