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)

Relevant section of the Policy: 2.4.1.
Cooperation with the Partners in order to inform the User on the available Content and Updates to which the User is entitled to

Relevant section of the Policy: 2.4.2.
Sending newsletters

Relevant section of the Policy: 2.4.3
Data controller
  • NNG
  • NNG
  • Partner
  • NNG
Scope of processed data
  1. Information processed related to the registration of the User:
    • User’s name;
    • User’s email address;
    • Country;
    • User Activity.
  2. Information processed related to the recognition of the SD card:
    • brand and model to identify the Device;
    • SWID (an ID created from the VIN using a one-way hash function);
    • IMEI (International Mobile Equipment Identity) number;
    • Software version;
    • first use date (the time of the first GPS fix of the navigation head unit);
    • VIN.
  • VIN;
  • date of the last Update;
  • version of the Update;
  • first use date (the time of the first GPS fix of the navigation head unit)
  • start and expiration of Mapcare Period.
  • User’s name;
  • User’s email address.
  • data processed with automated processing:
    • User’s interaction with the delivered newsletters (i.e. whether the email was opened, how many times the addressee clicked on it, whether the addressee read the entire email) and bounce rate of the emails;
    • OS and OS version of device the newsletter has been opened with;
    • type and version of email client of User;
    • type of device (including manufacturer of the device, whether the device qualifies as a phone, screen resolution)
    • IP address and geolocation data of device ( i.e. country/region information).
Legal basis
  • User’s consent.
  • User’s consent.
  • User’s consent.
Duration of data processing
  • The period during which the Update is available and supported by NNG, or until the User cancels his/her account or revokes his/her consent.
  • The period during which the Update is available (and supported by NNG, or until the User cancels his/her account or revokes his/her consent.
  • The period during which the Update is available and supported by NNG, 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 a Partner either inside the EEA or to North-America region (i.e. USA and Canada) depending on which regional website (EEA or NA) the customer is subscribing or which Device (EEA or NA) the customer is using when registering/logging in the Toolbox

  • VIN;
  • date of the last Update;
  • version of the Update;
  • expiration of Mapcare Period.

See detailed description of such data transfer under section 2.4.2 of this Policy.

Privacy Policy

This Privacy Policy (hereinafter referred to as the „Policy”) was published on and is effective as of 28 February 2019.

  1. 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 an SD card provided by the Partner together with the in-car navigation system built into your vehicle.

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

    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 period while Free Product is available and provided for the User (usually it is a three-year period).

    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: unsubscribe@nng.com

    Partners mean the following Mazda entities:

    • Mazda Motor Europe GmbH (Hitdorfer Strasse 73, 51371 Leverkusen, Deutschland);
    • Mazda North American Organization ( 200 Spectrum Center Drive, Irvine, CA 92618).

    Product means Updates, Content, and Connected Services. Software means the navigation software that runs on your Device.

    Profiling means automated processing of personal data, as listed in point 2.4.2.2 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 https://mazda.welcome.naviextras.com/

    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 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 or You means a registered visitor of the Site and/or theToolbox.

    User Activity means location and behaviour data (language selection in the Toolbox/on the Site, 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).

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

  2. PRIVACY POLICY

    1. Purpose of this document

      This Policy sets out 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!

    2. 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, 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.

    3. 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 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 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 section 2.4.2.2 of this Policy both NNG and the Partner qualify as data controller as described in section 2.4.2.5.

    4. Data processing

      1. Processing of data provided by the User during the registration on the Site and for the Toolbox

        1. Purpose of data processing

          1. 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.

            The process of carrying out an Update is the following: the User can remove the SD card from the navigation head unit manually. The SD card contains all information which is necessary to carry out an Update. The User shall insert the SD card to the PC and launch the Mazda Toolbox application. By using the Mazda Toolbox application information listed in section 2.4.1.2 b) is sent from the Toolbox to the NNG server.

          2. 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.

        2. Scope of the User’s processed personal data provided during the registration on the Site and in the Toolbox and for using the Toolbox:

          1. The following information is processed related to the registration of the User:

            • User’s name;
            • User’s email address;
            • Country of permanent or temporary residence;
            • User Activity.
          2. The following information is processed related to the recognition of the SD card:

            • brand and model to identify the Device;
            • SWID (an ID created from the VIN using a one-way hash function);
            • IMEI (International Mobile Equipment Identity) number;
            • Software version;
            • first use date (the time of the first GPS fix of the navigation head unit);
            • VIN.
        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 Site and Toolbox is retained for the period during which any Update or Product is available and supported by NNG, or until you cancel your account 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.

      2. Cooperation with the Partner 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 the Partner 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 Content). 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 the Partner. Partner 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 the Partners the following information:

          • VIN;
          • date of the last Update;
          • version of the Update;
          • first use date the time of the first GPS fix of the navigation head unit)
          • start and expiry of Mapcare Period.

          Both NNG and the Partners have a database containing all relevant VINs. The above pieces of information (date of the last Update, version of the Update, voucher code) are data generated in the system of NNG and can be established by way of comparing the two databases of VINs.

        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 the data processing

          Your personal data uploaded to the Site and Toolbox is retained for the period during which any Update or Product is available and supported by NNG, or until you cancel your account 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.

        5. Partners acting as controller

          1. The personal data of the Users are transferred to either Mazda Europe in case of Users subscribing on the European website or registering in Toolbox using European Device, or to Mazda North America in case of Users subscribing on the North American website or registering in Toolbox using North American Device Both Mazda Europe and Mazda North America are acting as data controllers in respect of personal data transferred to them. Partners process and stores the personal data in the territory of the EEA (in case of Mazda Europe) and in the USA or Canada (in case of Mazda North America).

          2. Partners qualify as data controllers in respect of personal data transferred to them and such data is processed by Partners in accordance with the provisions of their respective Privacy Policies (https://www.mazdamotors.eu/en/privacy-statement/ and (https://www.mazdausa.com/site/privacy). 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.

          4. Following the transfer of the personal data described in section 2.4.2.2, Partners are 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.

      3. 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. 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.

        2. Scope of the processed personal data of the User

          • User’s name;
          • User’s email address.

          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).
        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) 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.

        4. Duration of data processing and subscription to newsletters

          1. Your personal data uploaded to the Sita and Toolbox is retained for the period during which the Update is and your Device supported by NNG, or until you unsubscribe from the newsletter.

          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.

          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.

    5. Data processor

      1. Data processing related to the sending of newsletters

        1. 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.

        2. 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)
          • Collecting data of User’s registered Device and its geolocation (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)).
        3. The User data listed in section 2.4.3.2 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
    6. Cookies

      1. NNG hereby informs you that if you download certain parts of the Site and 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 pages or Toolbox features will be limited.

    7. Type of Cookie Purpose of Cookies Legal basis of data processing Cookie retention period
      Google Analytics The Site and the Toolbox uses 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 and the Toolbox from, and the pages they visited within the Site and the Toolbox. The collected data cannot be tracked back to the User. For further information on Google’s privacy policy, please 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 and the Toolbox, we send one or more Cookies provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to your computer to 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 and 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.
    8. 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.

    9. 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 oposes 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 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.

      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 of the GDPR.

    10. 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.