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 SIM card, Bluetooth, wireless internet access, or 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 to 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.
Customer Support means a service provided by Partner or its subcontractor for Users via web interfaces. Users may request Customer Support – among other things - for their Product purchases made on the Site.
Device means a device with GPS capability, such as
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.
NNG means NNG Software Developing and Commercial Limited Liability Company, which provides the Software and the Product.
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: email@example.com
Partner means the following entity
Privacy Act means Act CXII of 2011 on the right of informational self-determination and on freedom of information.
Product means Updates, Contents, and Connected Services.
Profiling means automated processing of personal data, as listed in point 184.108.40.206 in order providing the User with personalized newsletters relevant for the User and for his/her registered Device(s) in order to increase user experience and satisfaction;
Site means renault.naviextras.com and its subdomains.
Software means the navigation software that runs on your Device.
Toolbox means a free software tool for PC and OSX, which is used to download Updates and other Products from NNG’s servers and upload them to the Device.
Updates mean Content and Software updates, which are provided by your Device’s manufacturer or Software developer, and which provide additional features, new Content versions, or fix known Software problems.
User or "you" means a registered or not 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, and usage patterns (frequency/patterns of logging-in).
2.1. Purpose of this document
This Policy sets out the terms and conditions of how the User’s (hereinafter referred to as the “User” or “you”) personal data is processed. Please read these terms and conditions carefully!
2.2. Availability and updating of this document
NNG reserves the right to amend this Policy unilaterally at any time. We suggest visiting the Site and the 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.
2.3. Data controller
2.3.2.The provided or generated personal data of the User is accessible to the following persons within NNG:
· 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.
2.4. Data processing activities
2.4.1.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)
220.127.116.11. Purposes of data processing
a. Provision of information for the User about Products.
b. Providing the User with the purchased Products.
c. Administering registration on the Site and User account maintenance.
If the User wishes to download or purchase a Product, he/she shall register on the Site and download the Toolbox through the link available on the Site. By registering on the Site, the User also registers for the Toolbox.
· User’s title;
· User’s name;
· User’s email address;
· User’s hashed password;
· User’s address and invoice address;
· Country of permanent or temporary residence;
· User Activity.
18.104.22.168. 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.
22.214.171.124. Duration of data processing
User's personal data specified in point 126.96.36.199 is processed for the period during which any Product is available and supported by NNG or until User cancels his/her account on the Site or withdraws his/her consent. Notwithstanding the above, NNG shall immediately delete your personal data if you specifically request the deletion thereof or withdraws your consent and there is no valid legal ground for data processing. If the User withdraws his/her consent, this does not affect the lawfulness of data processing based on his/her consent and conducted before such withdrawal.
2.4.2.Processing of User's personal data for receiving newsletters
188.8.131.52. Purpose of data processing
NNG sends newsletters via email to inform the User about new Products and promotions, or other marketing activities. In order providing you with personalized newsletters relevant for you and your registered 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.
· User’s name;
· User’s email address;
· data related to User Activity;
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).
184.108.40.206. 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”).
The User can subscribe to NNG’s newsletter on the Site or in the Toolbox by ticking the appropriate checkbox. The User may withdraw his/her consent at any time by sending an email to NNG from the email account regarding which he/she does not wish to receive newsletters in the future, or by sending a mail to NNG’s postal address (the registered office) specified in section 1. The User may also unsubscribe (opt-out) at any time by following the instructions in the newsletter.
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.
220.127.116.11. Duration of data processing and subscription to the newsletter
18.104.22.168.1. User's personal data specified in point 22.214.171.124 is processed for the period during which the Update to your Device is available and your Device supported by NNG, or until you cancel your account on the Site or withdraw your consent. Notwithstanding the above, NNG shall immediately delete your personal data if you specifically request the deletion thereof or withdraws your consent and there is no valid legal ground for data processing. If the User withdraws his/her consent, this does not affect the lawfulness of data processing based on his/her consent and conducted before such withdrawal.
126.96.36.199.2. Please note that NNG may at any time decide to stop sending newsletters without prior notice, or further liability or obligation of any kind.
NNG transfers data typically generated in NNG’s system during the use of the Toolbox to the Partner so that the Partner can provide Customer Support to the Users. NNG provides access for the Partner to a surface where the Partner can see the data defined in section 188.8.131.52 of those Users who are registered in Partner’s system as well.
· user name used on the Site;
· type and number of the registered Device;
· services to which User is entitled to free of charge related to the Device;
· purchase history related to the Device;
· company name (completion is optional);
· phone number (completion is optional);
· fax number (completion is optional);
· billing address (completion is optional).
184.108.40.206. Legal basis of data processing
The legal basis of data processing will be the performance of a contract to which the data subject is a party, as set forth in point b) of Article 6(1) of the GDPR.
Processing User's personal data is essential for helping the provision of Customer Support by the Partner and performing NNG’s contractual obligations regarding thereof.
220.127.116.11. Duration of data processing
Your personal data specified in point 18.104.22.168 is processed for the period during which the Update to your Device is available and your Device is supported by NNG, or until you cancel your account on the Site. Notwithstanding the above, NNG shall immediately delete your personal data if you specifically request the deletion thereof.
22.214.171.124.1. The personal data are transferred to Partner acting as data controller. Partner processes and stores the personal data in EEA.
126.96.36.199.2. Partner qualify as data controller and such data is processed by Partner in accordance with the provisions of the. Such data processing is not covered by this Policy.
188.8.131.52.3. Following the transfer of the personal data described in section 184.108.40.206, Partner 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.
In order to fulfil its purposes as a data controller NNG cooperates with the data processors listed below. NNG reserves the right to change the data processors at any time.
2.6.1. 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 applicable data protection laws. These data files are necessary for the proper operation of the Site and the Toolbox, and are used to collect information on the User’s visits to the Site or in the Toolbox.
2.7. Data security
2.7.1. 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 and all relevant local laws concerning confidentiality and the security of data processing.
2.7.2. Salesforce.com 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. Salesforce.com has achieved ISO 27001/27018 certification for its ISMS from an independent third party.
2.8.1. 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.
2.8.2. 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.
2.8.3. 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.
2.8.4. 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.
2.8.5. If your personal data is inaccurate, you may request NNG to rectify such data, provided that the correct data is at NNG’s disposal.
2.8.6. 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.
2.8.7. 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.
2.8.8. You have the right to obtain restriction of processing from NNG in the following cases:
220.127.116.11. you think that your processed personal data is not accurate, for a period enabling NNG to verify the accuracy of your personal data;
18.104.22.168. the processing is unlawful and you opposes the erasure of your personal data, you are entitled to request restriction of their use instead;
22.214.171.124. 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;
126.96.36.199. you have objected to processing, for a period pending the verification whether the legitimate grounds of NNG override those of yours.
2.8.9. 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 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.
2.8.10. 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: firstname.lastname@example.org) or to the data protection authority of your home country or country of your residency.
2.8.11. 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.
2.8.12. Your detailed rights and remedies are set out in Articles 15-21 of the GDPR.
2.9. 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.