PRIVACY POLICY

Karta Software Technologies, Lda. (“Karta” or the “Company”) with registered office at Centro Empresarial da Lionesa, Rua da Lionesa 446, Pavilhão C25, 4465-671 Leça do Balio, Portugal and with company number 513 705 058, offer GPS navigation software for Smartphones and Automotive (the “Application” or the “Service”).

Our operations are subjected to European privacy laws: the General Data Protection Regulation (GDPR). The GDPR privacy rules are considered the most demanding set of regulations in the world, providing a high level of data protection. Our global policies on privacy and the handling of your personal data reflect these standards and, in some cases, constitute more stricter regulations.

It is Karta’s policy to respect your privacy regarding any information we may collect while operating our applications. For that reason, your personal data is only used by Karta, and, insofar as this is necessary, for companies with which Karta cooperates, as indicated in this privacy policy and it is never communicated to third parties for commercial purposes, without your prior consent.

This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, and delete your information. The provisions bellow apply to all End Users who use our Application.

This Privacy Policy is incorporated as part of the Karta Terms of Use and (the “Terms of Use” or the “Terms”).

Your use of the Application is subject to the Terms of Use, this Privacy Policy and indicates your consent to them.

Who Processes the Information?

Your personal data is processed by Karta, as the data controller according to the legal and regulatory provisions regarding personal data protection. If you have any further questions, please contact us by sending an e-mail to privacy@ndrive.com.

What information do we collect?

Certain features of the application require the collection of information about your device, and use of the application on the device, as described below.

For a better experience, while using our Service, we may require you to provide us with certain personally identifiable information. The information that we request will be retained by us and used as described in this privacy policy.

The information Karta collects, and how that information is used, depends on how you choose to use our Application and how you manage your privacy controls.

The app does use third party services that may collect information used to identify you, as described below. Here is the link to the privacy policy of third-party service providers used by the Application:

These third parties may only process your personal data in accordance with our instructions if they act as a processor. We equally guarantee that all these third parties have been selected with due care and are committed to ensuring the security and integrity of your personal data.

Information you create or provide to us

You may choose to share with Karta some information, including your language, “home” or “work” localizations, other “favourites”, car’s details, destinations you may travel to, search queries, if applicable. Also, when contacting our support, you provide us your email and name.

You may also provide additional information that will be used to personalize and enhance your experience with the Application. For example, if you provide us with your “home” and “work” information, we may provide you with what we think is the preferred route between those locations.

Information we collect as you use our Application

Karta collects non-personally-identifying information such as language preference, the date and time, and location of each visitor request. Karta’s purpose in collecting non-personally identifying information is to better understand how Karta’s users use its application. From time to time, Karta may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its Application.

We collect information about your activity in the Application, which we use to enhance it, including features which are meant to personalize your experience. This includes things like finding you the preferred route, proposing favourites or destinations commonly travelled by you to streamline your search and travel, and report of traffic incidents. The activity information we collect may include:

Our Service makes use of information about your actual location (“Location Data”) and information about places (“Place Information”). Location Data reveals Karta where you currently are or you have been. Location Data is based on available positioning methods, such as Assisted GPS. In many device models the user interface of the application identifies the use of positioning with an icon. Place Information is general information pertaining to particular geographical location (e.g., city or a location of a restaurant) that you may have provided to us. Unless otherwise stated, we use random identifiers in connection with your Location Data that do not identify you personally. When you start to use the application, it activates your selected positioning methods to retrieve your current location. The application may send your Location Data to Karta when you use location-enabled features of the application online, such as ask information about nearby suggestions, use search features. As further defined below, Location Data may be collected when you use the traffic feature for service improvement purposes without identifying you personally.

When this app is in use (or running in the background) we collect and share with our business partners (listed below under “Third Parties”) certain device and location data: Precise location data of the device, Wi-Fi signals or Bluetooth Low Energy devices in your proximity, device-based advertising identifiers, app names and/or identifiers, and information about your mobile device such as type of device, operating system version and type, device settings, time zone, carrier, and IP address.

That data may be used for the following purposes: (a) to customize and measure ads in apps and other advertising;(b) for app and user analytics; (c) for disease prevention (processing within the framework of the COVID-measures), and cybersecurity; (d) for market, civic or other research regarding aggregated human foot and traffic patterns, and (e) to generate proprietary pseudonymized identifiers tied to the information collected for the above purposes. For more details, please refer to the below section “How we use the information we have collected”. If you use the application in Belgium, we share, only after your prior consent, a small part of your location and trip data with the Flemish Road Authority (Agentschap Wegen en Verkeer). The shared location and trip data consists of a combination of location data (with departure buffer) and a unique session number. We do not share information that can be traced back to you directly (such as your name or email).

You may withdraw your permission of the above usages by accessing Settings Menuinside the Application, at any time, and from that moment on, no location and trip data will be shared anymore.

The Third parties that may collect such information used to identify you, are as listed:

We cooperate with third parties in some countries, such as local road authorities. In the case of a road authority, it receives specific information about traffic so that it can perform its services in a better manner (e.g. optimize traffic flows, better adjust traffic lights, etc.). You can help by sharing data. We only pass on this data if you give us your consent to do so. The transfer is limited to data that cannot be traced back to a user, such as location data, which are only linked to a unique session number. Thus, we do not provide account or payment information. In order to provide the data to that road authority, we ask you (on behalf of that road authority) for your prior consent. This way you keep maximum control over your data.

When you use the traffic features of the application, Location Data, speed, direction and timestamp are sent from your device to Karta to detect traffic jams, traffic patterns, changed road conditions and other such conditions so that we can provide you with better service. This information is analysed to distinguish independent routes and traffic patterns and contains an identifier, which is persistent for the duration of the route. You may choose the extent to which you contribute to the improvement of our services. In the context of traffic features of the Service, you can provide us with the Location Data, speed, direction and timestamp, along with the changing identifier. This information is sent to us when you use the application online after which it is deleted from your device. We do not use this data to identify you personally.

When you use the Service online, certain technical information such as the type of your cellular device, unique device or network service provider identifiers, Internet Protocol address, time zone, technical details of your platform as well as your transactions with Karta may be automatically collected by Karta.

This includes for example device model, operator, country, session and random, but persistent, identifiers in association with a particular event, for example start and stop events, menu accessed, feature selected or default value changed.

Karta may collect statistics about the behaviour of users to its application. Karta may display this information publicly or provide it to others. However, Karta does not disclose personally-identifying information other than as explicitly described in this Privacy Policy.

This includes information about error situations, for example which actions led to the error. However, no content, such as emails, SMS’s, documents, notes, search content, content of media files, exact location data (latitude and longitude) or any metadata which may be considered personal data or other such content is collected by the application.

How we use the information we have collected?

In the case of your personal data, we will process it only for the purposes stated in this Privacy Policy and if we have a legal basis for doing so.

The legal bases on which we rely are as follows:

Karta may use information collected from or provided by you for the following purposes:

The collected information helps us focus our improvement efforts to things that are most relevant to our users and to avoid error situations in the future. For example, Karta may use your route information to improve the accuracy of its mapping and navigation data. For these purposes, we may use information collected.

If you use the application in Belgium, (see section “What information do we collect > Locations data and place information”) your location and trip date will only be used by road authorities to assess and improve traffic situations, optimize traffic lights, monitor and evaluate traffic flows and traffic situations.

The information collected by the application is used to provide you with the service, to develop our products and services as well as to communicate with you. We may also use the information to provide you with more improved search and recommendations to better assist you to find a place you may like.

The Application may include provision of location based advertising or other similar content. You may be positioned separately for this purpose. For example, if you ask for weather information you may be served with advertising content tailored to that location. The Application may also include behaviourally profiled advertisements. For the purposes of provisioning relevant advertisements to you, we may share your device specific advertising ID to advertising networks. We use a third-party company called AdMob to deliver ads to you. The AdMob SDK collects information about your device while you use the application. This information may include, but is not limited to, your device identifier, model and related configuration (such as screen size), wireless communication operator, as well as IP address. In addition, we provide you with means to increase the relevance of the advertising you see in the app by sharing your location with the advertising network. If you wish to opt-out from behaviourally profiled advertising, you can always opt-out from your device settings. Note that in any case you may still receive ads, but just not profiled.

We use data for analytics and measurement to understand how our services are used. For example, we analyse data about your usage of the Application to do things like optimize product design. We also use the data we collected about the ads you view or interact with (e.g., click on) to help advertisers understand the performance of their ad campaigns and to provide them with aggregated reports. We may also use data to measure the effectiveness of Karta’s own marketing efforts on third party sites or platforms.

Your information is also used to send you updates, notices, announcements, users’ requests and additional information related to the Services, through push notifications.

Karta may also use your information to conduct surveys and questionnaires; and if you contact our support, we may keep a record of your request in order to help solve any issues you might be facing.

Karta may also use and process your information and content, using different technologies to the following purposes:

  1. To enforce the Terms of Use or Privacy Policy;
  2. To comply with any applicable law and assist law enforcement agencies under any applicable law, when Karta has a good faith belief that Karta’s cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures;
  3. To detect abuse and illegal activity; to detect and prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services;
  4. To handle breakdowns and malfunctions;
  5. To take any action in any case of dispute, or legal proceeding of any kind between you and Karta, or between you and third parties with respect to, or in relation with the Services;
  6. For purposes provided under this Privacy Policy and Terms of Use;
  7. To help improve the safety and reliability of our Services. This includes detecting, preventing, and responding to security risks, and technical issues that could harm Karta, its users, or the public;
  8. To create aggregated and/or anonymous data (where such data does not enable the identification of a specific user). See “How does Karta use aggregated information”, below;

Your consent will be asked for before using your information for a purpose that isn’t covered in this Privacy Policy.

How do we collect the information?

The application uses third-party software and services to collect and send information to Karta, as stated in the remaining sections of this Privacy Policy. Information sent consists of only a few kilobytes per instance.

How Karta uses aggregated information?

Karta may use anonymous, statistical or aggregated information (including pseudonymization on location information), in a form that does not enable the identification of a specific user, to properly operate the Application, to improve the quality of the Application, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes (including advertising).

Karta may also use anonymous, statistical or aggregated information collected on the Application, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to the Services’ providers, partners and any other third party. For example, GPS information that we receive from your mobile device may be provided to map editors in an aggregated and/or anonymous form to help improve the map and solve map problems, traffic data may be provided to cities and local authorities, and aggregated ads analysis may be provided to advertisers.

What are our information sharing practices?

We do not share the information collected by the application with independent third-parties, unless otherwise explained in our privacy policies. However, information collected of a particular third-party feature may be shared with the provider of that application or feature in aggregated non-identifiable form.

Karta will not share your personal information with others, without your permission, except for the following purposes and to the extent necessary in Karta’s good-faith discretion:

What safeguards are in place?

Information security is a top priority for us. Karta services are built with strong security features that continuously protect your information. Karta has all the necessary technical and organisational measures in place to process safely your personal data.

We have implemented systems, applications and protocols to secure your information, to minimize the risk of theft, damage, loss of information, or unauthorized access or use of information, whether on your device or on our servers. For example, we review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems. In addition, we restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations.

Notwithstanding the fact that Karta takes great efforts to protect your personal information, all the measures described above are unable to provide absolute assurance. Therefore, Karta cannot guarantee and you cannot reasonably expect that Karta’s databases will be absolutely immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

How long Karta retains the data collected?

Some data you can delete whenever you like, some data is deleted automatically, and some data will be retained for longer periods of time when necessary. This section describes why we hold on to different types of data for different periods of time.

Your personal data will only be processed for as long as necessary for the purposes stated in the section “How we use the information we have collected” to be fulfilled or, if applicable, until the moment you withdraw your consent. Please be aware that the withdrawal of your consent may mean that you are unable to use all or part of the Application.

Advertising Campaigns

Karta allows advertisers to run advertising campaigns on the Application.

The information and advertisements that you see when accessing the Application may be targeted on the basis of your current Karta activity, such as your current location, your destination or contextual information based on your current drive session. For example: if you search for “restaurant” you may see an ad for a local restaurant.

Depending on your settings, you may also see advertisements personalized to you based on:

You can decide whether we’ll show you personalized ads or not through our Application Settings > Terms & privacy > Location data & Ads. Please note that turning Ads personalization off does not turn off ads but only their personalization.

Also note:

The Application includes an internal messaging system which provides you the ability to receive marketing messages from us. You hereby agree that we may use the internal messaging system for the purpose of informing you regarding products or services, which may interest you.

It is clarified that we are not responsible for the content of said advertisements and the products delivered or services rendered thereby by third parties and you irrevocably and unconditionally agree that we shall not be held responsible or liable for any loss, damage, cost or expense that you may suffer or incur as a result or in connection thereof.

Your choices

The application offers a variety of choices to allow you to control how your Location Data and other information are collected. You may use the application in offline or online mode. No Location Data or other information is sent to Karta if you only use the application in offline mode. In offline mode, your device will also not interact with the advertising networks. Note, that your device may nevertheless continue to store and have already stored information which may be sent to Karta as defined earlier in this document and if you have enabled traffic feature. Note also that you may still receive ads, in case such ads have been cached in the device prior to switching the device into offline mode.

You can switch positioning services on and off using your device settings. Device positioning settings also control Karta positioning services. If you configure your device such that you are not using any assisted positioning methods, Karta positioning services will also not be used. You can choose to share your location with advertising networks to provide you with more location-relevant advertisements. You can always turn this on and off in the app settings. You may also clear your recent searches and destinations from the local storage of the Service. Clearing local storage will also clear already synchronized recent searches in the next synchronization instance.

Data subject rights and compliance

If you want to exercise your privacy rights relating to the Application, you may contact Karta and our data protection office at privacy@ndrive.com and your request will be acted upon according to law and the privacy policies applicable. And you can contact your local data protection authority if you have concerns regarding your rights under local law.

Your personal data are essentially processed within the European Economic Area (EEA).

In order to process your personal data for the purposes outlined in this Privacy Policy, we may also transfer your data to third parties processing them on our behalf outside the EEA. Any entity outside the EEA processing your data is required to observe adequate safeguards regarding the processing of your personal data. Such safeguards may arise from an adequacy decision the European Commission or contractual safeguards.

We may transfer anonymised and/or aggregated data to third parties outside the EEA. If such a transfer occurs, we will make sure that there are safeguards in place to ensure the security and integrity of your data and all rights regarding your personal data that you have under applicable legislation.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

Under the data protection laws applicable to the processing of your information, we provide the controls described in this policy so you can exercise at all times your right to request access to, update, remove, delete, and restrict the processing of your information.

You have the right to data portability, i.e., you can obtain from us all the personal data you provided to us in a structured, commonly used and machine-readable form if your data are processed by automated means and based on your consent or on a contract concluded with you.

You also have the right to object to the processing of your information and, if the processing of your personal data is based on your consent, you always have the possibility to withdraw such consent.

If you wish to exercise the above rights, it is possible, in some cases, to do so in your Application settings. You may also submit your request by sending an e-mail to privacy@ndrive.com. We will acknowledge receipt of your request. If your request is accepted, we will fulfil it as soon as reasonably possible and within thirty (30) days from the receipt of the request, at the latest.

We process your information for the purposes described in this policy, based on the following legal grounds:

  1. With your consent: we ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. You can manage your settings at any time, including your in-app Privacy Settings.
  2. When we’re pursuing legitimate interests: We process your information for our legitimate interests and those of third parties (such as partners including advertisers, in order to report use statistics) while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:
    1. Providing, maintaining, and improving our services to meet the needs of our users;
    2. Developing new services and features that are useful for our users;
    3. Understanding how people use our services (including how they interact with our ads) to ensure and improve the performance of our services;
    4. Customizing our services to provide you with a better user experience;
    5. Marketing to inform users about our services;
    6. Providing advertising, which keeps many of our services free;
    7. Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our services;
    8. Protecting against harm to the rights, property or safety of Karta, our users, or the public as required or permitted by law, including disclosing information to government authorities;
    9. Performing research that improves our services for our users and benefits the public;
    10. Fulfilling obligations to our partners like developers and rights holders;
    11. Enforcing legal claims, including investigation of potential violations of applicable Terms of Service.
  3. When we’re complying with legal obligations: We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process or an enforceable governmental request.

Privacy Policy Changes

Although most changes are likely to be minor, Karta may change its Privacy Policy from time to time, and in Karta’s sole discretion. In case of material changes, Karta will inform you in a timely manner of these changes and the date from which they apply. If we are unable to notify you of such change, you will be informed of the modified Privacy Policy the next time you use the application. In any case, Karta encourages users to frequently check this page for any changes to its Privacy Policy.

You agree to be bound by any of the changes made in the terms of this Privacy Policy. Your continued use of this application after any change in this Privacy Policy will constitute your acceptance of such change. If you do not agree with any of the amended terms, you must avoid any further use of Application.

Last modified: January 31th, 2023 Thank you and our promise

In choosing to provide Karta with information you are helping to make driving better, specifically by improving maps, traffic flows and reducing congestion. Thank you.

We promise not to give anyone else access to the information that we collect or use it for any other purpose than the ones details in this Privacy Policy, unless explicitly and lawfully ordered to do so following due legal process.