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.

Purpose of data processing	Providing access to the Content and Updates to which the User is entitled to, and providing a possibility to make a purchase by registering on the Site and for the Toolbox (or any other channel NNG may provide)	Cooperation with the Partners in order to provide Services in good quality	Sending newsletters
Data controller	NNG	NNG Partner 1 Partner 2	NNG
Scope of processed data	User’s first name; User’s last name; User’s email address; User’s address; User’s country of residence; User Activity.	VIN; User’s first name; User’s last name; User’s email address; User’s country of residence; Mapcare expiration date; Downloaded Updates.	User’s name; User’s email address.
Legal basis	User’s consent.	The legitimate interest of NNG and the Partners.	User’s consent.
Duration of data processing	The period during which the Update is available (during the production and expectedly 10 years following the end of the production), or until the User cancels his/her account.	The period during which the Update is available (during the production and expectedly 10 years following the end of the production), or until the User cancels his/her account.	The period during which the Update is available (during the production and expectedly 10 years following the end of the production), or until the User unsubscribes from the newsletter.
Data processor			Salesforce.com
Data transfer		NNG may transfer the following data of the User to the Partner 1 outside the EEA: VIN; Country of residence; Mapcare expiration date; Downloaded Updates. See detailed description of such data transfer under section 2.4.2 of this Policy.
Data transfer		NNG may transfer the following data of the User to the Partner 2 outside the EEA: VIN; Country of residence; Mapcare expiration date; Downloaded Updates. See detailed description of such data transfer under section 2.4.3 of this Policy.

PRIVACY POLICY

This Privacy Policy (hereinafter referred to as the „Policy”) was published on and is effective as of 15 August, 2018.

DEFINITIONS

Connected Services mean location-based services (local search, traffic information, fuel price, weather information, etc.), which require some form of online connectivity (data access via a SIM card or Bluetooth, wireless internet access, TMC receiver, etc.) on your Device.

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

Cookie means a small text file, which is placed on your hard disk by a web server, and is used by the Site and the Toolbox as set forth in section Privacy below.

Device means the in-car navigation system.

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

General Data Protection Regulation or 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 three-year period while Free Product is available and provided for the User.

NNG means NNG Software Developing and Commercial Limited Liability Company

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

Partner 1 means the following entity:

Company name:	Honda South America
Registered office:	Estr. Municipal Valêncio Calegari, 777, Bairro: Nova Veneza - Sumaré – SP, CEP: 13181-903, Brazil
Website:	http://www.honda.com.br/

Partner 2 means the following entity:

Company name:	Panasonic do Brasil Limitada
Registered office:	Av. Do Café, 277, Bloco A, 8 andar, Jabaquara CEP: 04311-900, São Paulo, Brazil
Website:	http://www.panasonic.com/br/

Product means Updates, Content, and Connected Services.

Software means the navigation software that runs on your Device.

Services mean the provision of Content and Updates for the User, informing the User on the available Content and Updates and provision of support for User by cooperating with Partner 1 and Partner 2.

Site means honda-sam.welcome.naviextras.com and its subdomains.

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

Updates mean Content and Software updates (available free of charge for a certain period, then for a fee), which are provided by your Device manufacturer or Software developer, and which provide additional features, new Content versions, or fix known Software problems.

User means a registered visitor of the Site and/or the Toolbox.

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

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

PRIVACY POLICY

Purpose of this document

This Policy sets 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!
Availability and updating of this document

NNG reserves the right to amend this document unilaterally at any time. We suggest visiting the Site and the Toolbox from time to time for the latest information.
Data controller
1. The data provided on the Site and in the Toolbox is processed by NNG.
2. The provided data is accessible to the following persons:
  - NNG’s employees involved in the data processing (including 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.
3. As regards the data described in sections 2.4.2.2 and 2.4.3.2 of this Policy, NNG, Partner1 and Partner 2 qualify as data controller as described in section 2.4.2.5 and section 2.4.3.5.
Data processing
1. Processing of User's personal data for providing access to the Products and administering registration on the Site and for the Toolbox (or any other channel NNG may provide)
  1. Purpose of data processing
    
    Provision of Updates
    
    If the User wishes to download or purchase a Product, he/she shall register in the Toolbox. By registering in the Toolbox, the User expressly and voluntarily gives his/her consent to NNG to process his/her personal data in compliance with the provisions of this Policy and the law on data protection.
  2. Scope of the User’s processed personal data provided during the registration for and use of the Toolbox:
    - User’s first name;
    - User’s last name;
    - User’s email address;
    - User’s address;
    - User’s country of residence;
    - User Activity.
  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) of Article 6(1) of the GDPR.
  4. Duration of data processing
    
    Your personal data uploaded to the Toolbox is retained for the period during which any Update or Product is available (during the production and expectedly 10 years following the end of the production), or until you cancel your account.
    
    Notwithstanding the above, NNG shall delete your personal data in case you specifically request the deletion thereof according to section 2.8 below.
2. Cooperation with Partner 1 in order to inform the User on the available Content and Updates to which the User is entitled to
  1. Purpose of data processing
    
    NNG transfers data defined in section 2.4.2.2 to Partner 1 for the following purpose:
    
    After the purchase of a vehicle, the User is entitled to download Updates and new Content (i) without any additional charge during the Mapcare Period and (ii) for a fee following the end of the Mapcare Period.
    
    As NNG is the technical provider of the Update, certain information is available to NNG only (e.g. information on whether the User has already updated the Software). Therefore, to provide the User with a good-quality service and to avoid sending notifications to a User who has already downloaded the new Content, NNG transfers the data described in section 2.4.2.2 to Partner 1. Partner 1 uses the transferred personal data for informing the User about the new Products during and after the Mapcare Period.
  2. Scope of the processed data
    
    NNG transfers to Partner 1 the following information:
    - VIN;
    - User’s country of residence;
    - Mapcare expiration date;
    - Downloaded Updates.
  3. Legal basis of data processing
    
    The legal basis of data processing is the legitimate interest pursued by NNG and Partner 1, as set forth in point f) of Article 6(1) of the GDPR.
    
    NNG conducted a balancing test on legitimate interest. The conclusion of the balancing test was that NNG's legitimate interest (interest in providing a good-quality service for the Users) is a lawful legal basis of the data processing. The legitimate interest of NNG overrides the rights and interest of the data subjects as there is no disproportionate negative impact on the data subjects' rights and interest since
    - it is undoubtedly in the interest of the User to get notified about new available Updates;
    - the User may reasonably expect such processing of their personal data;
    - only limited amount of personal data would be transferred and most of it cannot be obtained by Partner 1 from any other channel as it is technically generated in NNG’s system and
    - NNG implemented appropriate safeguards to minimize the risk of negative consequences.
  4. Duration of the data processing
    
    Your personal data uploaded to the Toolbox is retained for the period during which any Update or Product is available (during the production and expectedly 10 years following the end of the production), or until you cancel your account.
    
    Notwithstanding the above, NNG shall delete your personal data in case you specifically request the deletion thereof according to section 2.8 below.
  5. Partner 1 acting as controller
    1. The personal data are transferred to Partner 1 acting as data controller. Partner 1 processes and stores the personal data in the territory of Brazil. The personal data are transferred to Brazil based on point a) section 8 (2) of the Privacy Act and point c) Article 46 (2) of the GDPR as Partner 1 and NNG concluded and signed standard contractual clauses according to Decision C(2004)5721 of the European Commission. The copy of the standard contractual clauses can be obtained from NNG by sending an email to privacy@nng.com or a mail to NNG’s address (H-1037 Budapest, Szépvölgyi rd. 35-37.)
    2. Partner 1 qualifies as data controller and such data is processed by Partner 1 in accordance with the provisions of the Privacy Policy of Partner 1. Such data processing is not covered by this Policy.
    3. NNG does not process and therefore shall not be held liable for those further data, which you provided during the use of the service on the site of Partner 1.
    4. Following the transfer of the personal data described in section 2.4.2.2, Partner 1 is directly liable for the processing of such data. Should any claim occur related to the data processing, as from this date, the User shall address such claim directly to Partner 1.
3. Cooperation with Partner 2 in order to provide the User support related to the Services
  1. Purpose of data processing
    
    NNG transfers data defined in section 2.4.3.2 to Partner 2 for the following purpose:
    
    Partner 2 provides support for Users and as part of such support Partner 2 is expected to answer questions related to Updates. To this end Partner 2 needs the information described below. For the provision of Services in good quality, NNG cooperates with Partner 2 regarding such data transfer.
  2. Scope of the processed data
    
    NNG transfers to Partner 2 the following information:
    - VIN;
    - User’s country of residence;
    - Mapcare expiration date;
    - Downloaded Updates.
  3. Legal basis of data processing
    
    The legal basis of data processing is the legitimate interest pursued by NNG and Partner 2, as set forth in point f) of Article 6(1) of the GDPR.
  4. Duration of the data processing
    
    Your personal data uploaded to the Toolbox is retained for the period during which any Update or Product is available (during the production and expectedly 10 years following the end of the production), or until you cancel your account.
    
    Notwithstanding the above, NNG shall delete your personal data in case you specifically request the deletion thereof according to section 2.8 below.
  5. Partner 2 acting as controller
    1. The personal data are transferred to Partner 2 acting as data controller. Partner 2 processes and stores the personal data in the territory of Brazil. The personal data are transferred to Brazil based on point a) section 8 (2) of the Privacy Act and point c) Article 46 (2) of the GDPR as Partner 2 and NNG concluded and signed standard contractual clauses according to Decision C(2004)5721 of the European Commission. The copy of the standard contractual clauses can be obtained from NNG by sending an email to privacy@nng.com or a mail to NNG’s address (H-1037 Budapest, Szépvölgyi rd. 35-37.)
    2. Partner qualify as data controller and such data is processed by Partner 2 in accordance with the provisions of the Privacy Policy of Partner 2.. Such data processing is not covered by this Policy.
    3. NNG does not process and therefore shall not be held liable for those further data, which you provided during the use of the service on the site of Partner 2.
    4. Following the transfer of the personal data described in section 2.4.3.2, Partner 2 is directly liable for the processing of such data. Should any claim occur related to the data processing, as from this date, the User shall address such claim directly to the Partner 2.
4. Processing of data provided by the User for receiving newsletters
  1. Purpose of data processing
    
    NNG sends newsletters to inform the User about new Products and promotions, or other marketing activities.
  2. Scope of the processed personal data of the User
    - User’s name;
    - User’s email address.
  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
    1. the User’s express consent given pursuant to point a) in Article 6(1) of the GDPR and
    2. 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 to the Site or into the Toolbox is retained for the period during which the Update is available (during the production and expectedly 10 years following the end of the production), or until you unsubscribe from the newsletter.
    2. The User can subscribe to NNG’s newsletter on the Site or in the Toolbox. By ticking the appropriate checkbox, the User voluntarily gives his/her consent that NNG sends him/her a newsletter from time to time. NNG may send personalized newsletters to the User based on the data processed in compliance with this Policy.
    3. The User may withdraw his/her consent at any time by sending an email to NNG from the email account in which he/she does not wish to receive newsletters in the future, or by sending mail to NNG’s address specified in section 1. The User may also unsubscribe (opt-out) at any time by following the instructions in the newsletter.
    4. Please note that NNG may at any time decide to stop sending newsletters without prior notice, or further liability or obligation of any kind.

Data processor

Data processing related to the sending of newsletters

For sending newsletters to the Users, NNG cooperates with a data processor, which provides email marketing services. 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.
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).

The User data listed in section 2.4.4.2 is stored both in the System and on NNG’s server.

Name of NNG’s data processor:	salesforce.com EMEA Limited
Address of the data processor:	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

Cookies
1. NNG hereby informs you that if you download certain parts of the Site or the Toolbox, small data files (“Cookies”) will be automatically sent by the web server to your Device. In certain cases, these data files may be considered as personal data under the Hungarian law on privacy. These data files are necessary for the proper operation of the Site and the Toolbox, and are used to collect anonymous information on the User’s visits to the Site or in the Toolbox.
2. The User can accept or refuse Cookies on a case-by-case basis, or refuse all Cookies by adjusting his/her browser settings. To find out how to do this and learn more on Cookies, please visit: https://www.youronlinechoices.eu/. If the User chooses to refuse all Cookies, the access to some Site or Toolbox features will be limited.

Type of Cookie	Purpose of Cookies	Legal basis of data processing	Cookie retention period
Google Analytics	The Site and the Toolbox use the Google Analytics tool to collect and analyse information on how the User uses the Site and the Toolbox. We use the information to compile reports and improve the Site and the Toolbox. The data is collected in an anonymous form, including the number of Users to the Site and the Toolbox, where Users have come to the Site or the Toolbox from, and the pages they visited within the Site or the Toolbox. The collected data cannot be tracked back to the User. For further information on Google’s privacy policy, click here.	User’s consent.	Google Analytics Cookies are created as soon as the User visits a website on which a valid Google Analytics tracking code is installed. The Cookies will be held in the User's browser for a maximum period of 2 years from the above date. For further information, please click here.
Google AdWords (Google Remarketing)	Third-party service providers, including Google, store previous visits made by a User to the Site and the Toolbox, and use this information to display NNG’s advertisements to the User on the websites of Google’s partners. When the User visits the Site or the Toolbox, we send one or more Cookies provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to your computer, which uniquely identify your browser. Google’s remarketing Cookies are used in Google AdWords. The Cookies provided by Google remember the number and times of visits to the Site or the Toolbox, as well as the sub-pages viewed by the User when browsing the Site or the Toolbox. The recorded data is stored anonymously. The User can block Google’s remarketing Cookies on the opt-out page of Google’s Ads Settings, and can also block third-party Cookies on the Network Advertising Initiative opt-out page.	User’s consent.	The AdWords Cookies expire 90 days after the User visited the Site or the Toolbox. For further information, please click here.
Session ID	Session Cookies allow the User to be recognized within the Site or the Toolbox. The most common example of this functionality is the shopping cart feature of the Toolbox. When the User visits a page of a catalogue and selects some items, the session Cookie remembers the selection, so the shopping cart will contain the selected items when the User is ready to check out.	User’s consent.	The information is saved until the end of the current session. After that, the collected information will no longer be available.

Data security
1. NNG observes all applicable regulations regarding the security of personal data, therefore both NNG and its authorized data processor implement appropriate technical and organizational measures to protect personal data, and establish adequate procedural rules to enforce the provisions of the Privacy Act concerning confidentiality and the security of data processing.
2. The data processor is compliant with the requirements of an information security management system (ISMS) specified by the ISO 27001 international standard, and meets the criteria of ISO 27018. The data processor has achieved ISO 27001/27018 certification for its ISMS from an independent third party.
Rights and remedies
1. Any personal information which you provide for NNG must be true, complete, and accurate in all respects. You agree to notify us of any change in your personal information via NNG’s email address specified in section 1 without delay.
2. The User may exercise the following rights in relation to NNG's data processing activities:
  - Request information on the processing of his/her personal data;
  - Request the rectification of his/her personal data;
  - Request the deletion of his/her personal data or restriction of the processing of his/her personal data;
  - Object to NNG's data processing;
  - Request data portability.
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 by sending an email or mail to the email or postal address (registered office) specified in section 1. 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. Your request for data deletion may be submitted to NNG by using the email or postal address (registered office) specified in section 1. 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.
7. 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.
8. 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.
9. 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 to 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.
10. 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: H-1125 Budapest, Szilágyi Erzsébet fasor 22/C.; postal address: 1530 Budapest, Pf. 5; 5 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.
11. Independently from lodging a complaint to NAIH, you may turn to court pursuant to the provisions set forth in the Privacy Act 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.
12. Your detailed rights and remedies are set out in Articles 15-21 and 77-82 of the GDPR.
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 an email or mail to the email or postal address specified in section 1. We will handle the submitted information confidentially. Our representative will contact you within a reasonable time.