|Purpose of data processing||Registration to the Toolbox||Sending newsletters|
|Scope of the processed data||
|Duration of data processing||
Anonymous Data means information that is not associated with or linked to your personal data; therefore, the Anonymous Data cannot be used for identification purposes.
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 Toolbox as set forth in section Privacy below.
Device means an SD card provided by Partner and the in-car navigation system.
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: email@example.com
Partner means the following entities collectively:
- Mazda Motor Corporation (3-1 Shinchi, Fuchu-cho, Aki-gun, Hiroshima 730-8670 Japan)
- Mazda Motor Europe GmbH (Hitdorfer Strasse 73, 51371 Leverkusen, Deutschland)
- Mazda North American Operations (PO Box 19734, Irvine, CA 92623-9734)
Product means Updates, Contents, and Connected Services.
Software means the navigation software that runs on your Device.
Toolbox means a free software tool for PC and OSX, which can be 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 Toolbox.
User Activity means location and behaviour data (language selection in the Toolbox/website, products put in the User's cart), onsite browsing history, usage patterns (frequency/patterns of logging-in to investigate fraud, misuse of the Toolbox/website).
2.1. 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 or anonymous information is processed. Please read these terms and conditions carefully!
2.2. Availability and updating of this document
NNG reserves the right to amend this document unilaterally at any time. We suggest visiting the Toolbox from time to time for the latest information.
2.3. Data controller
2.3.1. The data provided in the Toolbox is processed by NNG
2.3.2. 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.
2.3.3. Any personal information which you provide for NNG must be true, complete, and accurate in all respects. You agree to notify us of any changes to your personal information via NNG's e-mail address specified in section 1 without delay.
2.4. Data processing
2.4.1. Processing of data provided by the User during the registration for the Toolbox
188.8.131.52. Purpose of data processing
a. Contacting the User in order to inform him/her about the Free Product to which he/she is entitled.
After the purchase of a vehicle, the User is entitled to download new Content and receive Connected Services without any additional charge (“Free Product”) for a fixed period.
To provide the User with the Free Product, both NNG and the Partner intends to send notification emails to the User registered in the Toolbox or in the Partner's database. The aim of such newsletters is to inform the User about the availability of the Free Product to which he/she is entitled.
As NNG is the technical provider of the Free Product, certain information is available to NNG only (e.g. no information on whether the User has already downloaded the latest free map is available in the Partner's database). Therefore, to provide the Free Product for the User in good quality and to avoid sending notifications to a User who has already downloaded the new Content, NNG provides the Partner with the following information:
- Whether the User has already activated the Free Product;
- Whether the User has already downloaded the Free Product;
- The remainder of the period of entitlement to the Free Product.
By comparing this information in NNG's and the Partner's databases, it can be decided whether the User is entitled to a Free Product.
b. Provision of Updates
If the User wishes to download or purchase a Product, he/she shall register 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.
184.108.40.206. Scope of the User's processed personal data provided during the registration for and use of the Toolbox:
- User's name;
- User's email address;
- User's address;
- Country of permanent or temporary residence;
- User Activity.
220.127.116.11. Legal basis of data processing
a) The data is processed in compliance with Act CXII of 2011 on the right of informational self-determination and on freedom of information (“Privacy Act”). The legal basis of data processing is the User's consent given pursuant to point a) of section 5(1) of the Privacy Act.
b) As of 25th May 2018, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 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 (“General Data Protection Regulation” or “GDPR”) shall apply. As of this date, 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) in Article 6(1) of the GDPR.
18.104.22.168. Duration of data processing
Your personal data uploaded to the Toolbox is retained for the period during which any Update or Product is available (expectedly 10 years), or until you cancel your account.
Notwithstanding the above, NNG shall immediately delete your personal data if you specifically request the deletion thereof.
22.214.171.124. Registration number of such data controlling: NAIH-115998/2017.
2.4.2. Processing of data provided by the User for receiving newsletters
126.96.36.199. Purpose of data processing
NNG sends newsletters to inform the User about new Products and promotions, or other marketing activities.
188.8.131.52. Scope of the processed personal data of the User
- User's name;
- User's email address.
184.108.40.206. Legal basis of data processing
a) The data is processed in compliance with Act CXII of 2011 on the right of informational self-determination and on freedom of information (“Privacy Act”) and Act XLVIII of 2008 on the basic requirements and certain restrictions of commercial advertising activities (“Advertising Act”).
The legal basis of data processing is
- the User's consent given pursuant to point a) of section 5(1) of the Privacy Act and
- the User's consent given pursuant to sections 6(1) and (2) of the Advertising Act.
b) As of 25th May 2018, the GDPR shall apply. As of this date, the legal basis of data processing will be the consent of the data subject, as set forth in point a) in Article 6(1) of the GDPR.
220.127.116.11. Duration of data processing and subscription to the newsletter
18.104.22.168.1. Your personal data uploaded to the Toolbox is retained for the period during which the Update is available (expectedly 10 years), or until you unsubscribe from the newsletter.
22.214.171.124.2. The User can subscribe to NNG's newsletter 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.
126.96.36.199.3. 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.
188.8.131.52.4. Please note that NNG may at any time decide to stop sending newsletters without prior notice, further liability or obligation of any kind.
184.108.40.206.5. Registration number of such data controlling: NAIH-115997/2017.
2.5. Data processor
2.5.1. Data processing related to the sending of newsletters
220.127.116.11. The data is processed on behalf of NNG by a data processor, which provides email marketing services.
18.104.22.168. To improve user experience, the data is processed for the following purposes:
- Sending emails to email addresses provided by NNG;
- Analysing the activities in the delivered email (in particular whether the email was opened, how many times the addressee clicked on it, whether the addressee read the entire e-mail) and sending feedback to NNG;
- Analysing the bounce rate (e.g. cases in which the email address is invalid or the email is listed as spam).
22.214.171.124. The data processor has access to the User data listed in section 4.2.2, uploaded by NNG.
Such information is used to send emails on behalf of NNG. The data processor has access to this information for a period established by NNG from time to time, and it shall delete such data upon NNG's request. NNG reserves the right to change the data processor at any time.
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
2.6. Anonymous Data
2.6.1. The Toolbox also collects Anonymous Data (including your internet protocol address, browser type, operating system, browser language, screen resolution, etc.) with automated logging mechanisms running on our servers. The purpose of such logging is:
- system security and data protection;
- usage statistics;
- optimization and improvement of the Toolbox.
2.6.2. This Anonymous Data is not associated with any of the User's personal data, thus it is not used for identifying the User.
2.7.1. NNG hereby informs you that if you download certain parts of 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 Toolbox, and are used to collect anonymous information on the User's visits in the Toolbox.
|Types of cookie||Purpose of the cookies||Legal basis of data processing||Cookie retention period|
|Google Analytics||The Toolbox uses Google Analytics tool to carry out access measurements and to collect information about how Users use the Toolbox. We use the information to compile reports and to help us improve the Toolbox. The data is collected in an anonymized form, including the number of Users to the Toolbox, where Users have come to the Toolbox from and the pages they visited within the Toolbox. The collected data cannot be tracked back to a User. For further information on Google’s privacy click here.||User’s consent.||Google Analytics Cookies are created as soon as User visits a website on which a valid Google Analytics tracking code is installed. 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 Toolbox and use this information to display NNG’s advertisements on the websites of Google’s partners for the user.
When visiting the Toolbox, we send one or more cookies provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to your computer that uniquely identifies your browser. Google Remarketing cookies are used through Google AdWords. The cookies provided by Google remember the number and times of visits to the Toolbox, as well as the sub-pages viewed by a user when browsing the Toolbox. The data recorded is stored anonymously.
Users can block Google Remarketing cookies on the page dedicated to turning off cookies under Google’s ads settings, and users can also block third-party cookies on the Network Advertising Initiative opt-out page.
|User’s consent.||AdWords cookies expire 90 days after User visited the Toolbox.
For further information please click here.
|Session ID||Session cookies allow Users to be recognized within the Toolbox.
The most common example of this functionality is the shopping cart feature of the Toolbox. When User visits one page of a catalogue and select some items, the session cookie remembers the selection so the shopping cart will have the items selected when the User is ready to check out.
|User’s consent.||The information is saved until the end of a session. After that, the collected information will no longer be available.|
2.8. Data security
2.8.1. 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.
2.9. Rights and enforcement
2.9.1. The User may request the following from NNG as data controller:
- Information on the processing of his/her personal data;
- Rectification of his/her personal data; and
- Deletion or blocking his/her personal data (unless the processing of the personal data is mandatory).
2.9.2. You are entitled to request information on the data processing carried out by NNG, 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 specified in section 1. NNG shall provide written information on the processing of your personal data within 25 days after receipt of the request, in writing. You may also request the correction or blocking of your personal data.
2.9.3. If your personal data is inaccurate, you may request NNG to rectify such data, provided that the correct data is at NNG's disposal.
2.9.4. Your data shall be deleted upon your request. Your request for data deletion may be submitted to NNG by using the email or postal address specified in section 1. NNG shall delete all stored personal data in compliance with this Policy.
2.9.5. The personal data shall be blocked instead of being deleted if so requested by the User as a data subject, or if there are reasonable grounds to believe that the deletion could affect the legitimate interest of the User.
2.9.6. Please be informed that your data will not be deleted if the processing thereof is required by law.
2.9.7. 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).
2.9.8. 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.
2.9.9. Your detailed rights and remedies are set out in subsections 14–18 and 21–23 of the Privacy Act.
2.10. Contact 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.
3. USE OF THE TOOLBOX
3.1. Purpose of this document
3.1.1. This document lays down the term of use of the Toolbox. Please read these terms and conditions carefully!
3.1.2. By using the Toolbox in any manner, you accept all the terms and conditions herein. You also agree that we may amend and/or revise this document at our discretion, and you agree to be bound by these revisions and amendments. We suggest visiting the Toolbox frequently for the latest information.
3.1.3. If you do not agree with these terms and conditions, we request that you immediately cease using the Toolbox.
3.2. Operation of the Toolbox
The Toolbox is operated by NNG.
3.3. Services provided by the Toolbox
- Detailed description of Updates, navigation Content for Users via e-delivery (download from the Internet);
- Possibility to purchase or download Products on your Device;
- Possibility to subscribe to newsletters.
3.4. Registration in the Toolbox
3.4.1. User registration
Some features of the Toolbox are available to registered Users only. Buying or getting free Updates, Contents, or Services requires User registration. Registration is easy and free. To the processing of the User's personal data, the provisions of this Policy shall apply.
Please do not to share your username and/or password with any third party, or otherwise give any third party access to the Toolbox with your login data. You assume all responsibility for any unauthorized use of any username or password assigned to you.
You can delete your profile (with all your personal data) in the Toolbox at any time.
3.4.2. Registration of a Device
Registered Users may also decide to register their Devices. This is optional, but the Toolbox can only ensure the compatibility of Updates, Content, and Services if the User's Device or Software is previously registered with the Toolbox, thus allowing the Toolbox to check compatibility prior to the purchase.
3.5. Content available in the Toolbox
- The texts, illustrations, and pictures displayed in the Toolbox are for information purposes only, and shall not be considered as an offer. NNG does not make any representations regarding the correctness, accuracy, timeliness, or completeness of the content available in the Toolbox. NNG reserves the right to change such information at any time, without prior notice. The information published in the Toolbox may refer to products, programs, or services that are not available in your country. Such references do not imply that NNG intends to sell such products, programs, or services in your country.
- NNG shall not be liable for any direct or consequential damage, loss of profit, or additional costs, or damage of any kind resulting from the use of the Toolbox, or of false, incorrect, or incomplete content.
3.6. The User's obligations
- You agree not to interfere with, disrupt, or attempt to interfere with or disrupt the operation of the Toolbox or of the networks connected to the Toolbox, and you agree to abide to all security policies.
- The User may not upload or otherwise publish any content in the Toolbox, which is illegal in any way (copyrighted or illegal due to moral or other reasons).
3.7. Limiting User access
NNG may at any time limit your access to the Toolbox or some parts of the Toolbox, at its sole discretion, as appropriate or necessary for security or business reasons, as a result of any alleged or suspected breach of these terms, or to protect intellectual property. The Toolbox may also impose limits on certain features or restrict your access to parts, or all of the Toolbox without prior notice, or any liability therefor. NNG may delete any User account and/or suspend User login without any prior notice.
3.8. Availability of the Toolbox
We do not guarantee 24/7 reliable operation, availability, or uptime of the Toolbox, but we do make all reasonable efforts to ensure high availability.