Privacy policy

NDrive Navigation Systems, SA (“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 508141184, offers Location-Based services.

Privacy is of the utmost importance to us. Being based in Europe, our operations are subject to European privacy laws and regulations: GDPR. GDPR privacy rules are one of the strictest regulations of the World. Our Global Privacy policies reflect these regulations.

To read who has access to your information, get information about your rights and where we store your data, jump to ‘MORE INFORMATION’.
This Privacy Policy was last modified on June 30 th , 2023 and subject to change at any time with or without further notice. We encourage you to frequently check this page for any updates.

Our online presence displays information regarding products, features and services. You can reach our customer support team, read walkthroughs and learn more about the Company. We can use your email addresses solely for the purpose of future support communications. We collect, analyze and process data related to the way our users interact with the website in order to improve the way we communicate with our users.

You can go to ‘More Information’ to read who has access to your information, get information about your rights and where we store your data.

When you visit one of our offices, we will register upfront your name, email, company details and NDrive’ s contact person for security and safety purposes and retain this data for a limited period of time after your visit.
We also use CCTV monitoring of entrances and office spaces for safety and security reasons, and delete this data within a maximum period of 30 days unless we need it longer for further investigations.

When applying for a job at NDrive, we will request some details from you to start the application process. During this process we ask for your name, date of birth, email address, resume with education and experience, cover letter and availability. We could also contact you to fill in a candidate survey to hear more about your experience. These (aggregated) results will be used for internal analysis and reporting and kept for the communicated duration. For some vacancies, a test, assessment or development case could be required and we process the results to decide whether you can continue to the next round. This information will be retained in accordance with the applicable data retention regime unless you have explicitly agreed to another retention period.

When we make you a job offer, we could ask for a referral and further details to ensure a proper onboarding, such as identity documentation and number, marital status, certificates, banking details and any other information which will be explicitly requested in our onboarding documentation.

To read who has access to your information, get information about your rights and where we store your data, jump to ‘More Information’.

What is our legal basis for using your personal data?

When you download one of our apps we need minimum information to enable you to use features safely and properly. Certain features of the application require the collection of information about your device, and use of the application on the device, as described in more detail in the app’s Privacy Policy. For a better experience, while using our Services, 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 NDrive collects, and how that information is used, depends on how you choose to use our app and how you manage your privacy controls. You can easily change your permissions in the settings of your app. Withdrawing your consent could mean that some services are no longer available.

In some cases, we process your data in NDrive’ s legitimate interest to better manage our products and services – helping keep them working as expected, keep them secure, and improve the customer experience by looking at how and when you use them. This processing is subject to appropriate measures to protect your identity in accordance with industry practices, taking into consideration the risk represented by the processing and the nature of the data being protected. We have taken appropriate steps to address security, risk of data loss and other risks taking into consideration the nature of the data, the kind of processing activities and assigned responsibilities to address security and privacy related matters.

How can you manage your personal data?

You can access your personal data, obtain a copy, have incomplete, incorrect, unnecessary or outdated data updated or request that your data will be deleted. You have the right to object to or restrict processing in certain circumstances, such as when you believe the data is inaccurate or the processing activity is unlawful. To execute your access and deletion rights, you can contact us directly using the contact details on our website or using the dedicated email privacy@ndrive.com . Some of NDrive’ s products give you the option to directly access or delete your data.

Who has access to your personal data?

We don’t sell or disclose your personal data to other parties unless otherwise stated below. NDrive only shares your information with companies or organizations connected or affiliated with NDrive, such as subsidiaries, sister-companies and parent companies, that are responsible for services and products, and with NDrive’s trusted partners and service providers, when necessary, to process that information for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures. For example, we use service providers to help us with customer services.

Be aware that your device’s operating system, other apps running on your device or the communication networks collect, transmit and store your personal and location information. NDrive has no influence over this. For more details you can check the statement and settings from your mobile operator, device manufacturer and other app developers. When you share your information directly with a third party, for example posting details on social media, the third party will process that information in accordance with its own privacy policies. Our product privacy settings contain more information on embedded third-party services, you can check these for more details.

We promise not to give anyone else access to your information unless we have a compulsory legal obligation to do so, for example when we are obliged by applicable law to disclose your information to governments, competent authorities and law enforcement agencies or to defend NDrive’ s legitimate interests in legal proceedings.

Where do we store your personal data?

We store, hold and manage your personal information through our servers located in Portugal or through cloud based or hosting services or a third party or a party affiliated or connected to NDrive, as reasonable for business purposes, which may be located in the European Economic Area (EEA) or other countries outside the EEA with different regulations on data protection. In these cases, we assess that your privacy is protected in the best way possible and that an adequate level of data protection is met, for example through an official adequacy decision or appropriate safeguards with standard contractual clauses subject to additional risks assessments.

How long do we store your personal data?

We don’t save and use your information longer than necessary. We delete all data related to you afterwards. In some cases, we continue to use anonymous or de-identified information, when specific data is needed for further analyses, product improvements and reports. The length of time that we retain personal data and criteria for determining that time, are dependent on the nature of the personal data, our legal obligations and the purpose for which it was provided.

Do you have any questions or complaints?

You can contact NDrive’ s Data Protection Officer at:
NDrive, Navigation Systems, S.A.
A/T Data Protection Officer
Centro Empresarial da Lionesa
Rua da Lionesa, 446, Pav. C25
4465-671 Leça do Balio
Portugal
Email: privacy@ndrive.com

If you’re not satisfied, you can also contact the Portuguese Data Protection Authority.

Who’s responsible for your personal data?

NDrive, Navigation Systems, S.A., with headquarters at Centro Empresarial da Lionesa, Rua da Lionesa, 446, Pav. C25, 4465-671 Leça do Balio, Portugal is responsible for your personal data in relation to NDrive’s products and services. NDrive’s affiliates providing specific products or services may be (joint) controller or (sub) data processor of your data. You can find more information about these affiliates in the product legal terms and conditions available through the product settings or our website.

Karta Software Technologies, Lda. (“Karta” or the “Company”) is an affiliated company of NDrive, 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, that offers 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.

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 .

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:

• Consent: your free consent, given after being informed of its implications.
• Legitimate interest: a legitimate interest that we as an organisation have, for example, the optimization of our products and services delivered.
• Legal obligation: a legal obligation to which we are subjected.

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

• Improvement of products and services

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.

• Provision of the Services

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.

• Location based advertising

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.

• Performance measure

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.

• Communication with you

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.

• Protection of Karta, its users, the public and for Legal reasons

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:

• As necessary for the facilitation and operation of the Services.
• If Karta reasonably believes that you have breached the Terms of Use or is investigating potential breach of the Terms of Use, or believes that you abused your rights to use the Services, or performed any act or omission that Karta reasonably believes to be violating any applicable law, rules, or regulations. Karta may share your information in these cases, with law enforcement agencies and other competent authorities and with any third party as may be required to handle any result of your wrongdoing;
• If Karta is required, or reasonably believes that it is required by law to share or disclose your information;
• In any case of dispute, or legal proceeding of any kind between you and Karta, with respect to, or in relation with the Services;
• In any case where Karta reasonably believes that sharing information is necessary to protect against harm to the rights, property or safety of Karta, our users, or the public as required or permitted by law, including to prevent imminent physical damage or damage to property;
• To detect, prevent, or otherwise address fraud, security, or technical issues;
• If Karta organizes the operation of its Services within a different framework, or through another legal structure or entity, or if Karta is acquired by, or merged into or with another entity, or if Karta enters bankruptcy, provided however, that those entities agree to be bound by the provisions of this Privacy Policy, with respective changes taken into consideration;
• To collect, store, hold and manage your personal information through cloud based or hosting services or a third party or a party affiliated or connected to Karta, as reasonable for business purposes, which may be located in the European Union and the U.S.A., potentially countries outside of your jurisdiction;
• Karta may also share personal information with companies or organizations connected or affiliated with Karta, such as subsidiaries, sister-companies and parent companies;
• We work with other Google’s services (such as Google AdMob and AdSense) for advertising and ad measurement purposes. In order to help advertisers decide what ads to show on Karta, Google, and websites & apps that partner with Google, we may share information with these services, such as a unique identifier for advertising (i.e., Advertising ID available on Android mobile devices or similar technologies). For more information see section titled ‘Advertising campaigns’ under this Privacy Policy.
• We also work with selected advertising and measurement services which help us understand how our users interact with ads served in our Application and in order to provide marketing, advertising and measurement services for Karta with respect to Karta’s own marketing efforts, by using and sharing devices’ identifiers (i.e., Advertising ID or similar technologies).
• Personal information may also be shared with Karta’s trusted partners and service providers to process it for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures. For example, we use service providers to help us with customer services.

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.

• Information retained until you remove it – such as your “Home, “work”, favourites, and other related information. We’ll keep this data in your Application until you choose to remove it and/or update it.
• Data that expires after a specific period of time – in some cases, you don’t need to actively delete your information as we set retention timeframes based on the reason for the data’s collection. For example, when you use the traffic features of the application we collect anonymous location data for real-time traffic. After 5 minutes all data shared is no longer real-time and valid and is therefore deleted from servers automatically.
• Information retained for extended time periods for limited purposes – sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. For example, if Karta processes a payment for you, we’ll retain this data for longer periods of time as required for tax or accounting purposes. Reasons we might retain some data for extended periods of time include:
  • Security, fraud & abuse prevention;
  • Financial record-keeping;
  • Complying with legal or regulatory requirements;
  • Ensuring the continuity of our services, and;
  • Direct communications with Karta.

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:

• Information we received from you (for example, your saved “Home” & “Work” addresses);
• Past activity and search query history (for example, drives that appear in your drive list);
• Information from our ad partners.

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:

• We don’t knowingly collect nor do we show you personalized ads based on sensitive categories, such as race, religion, sexual orientation, or health.
• We don’t share information that personally identifies you with advertisers, such as your name or email, if provided for any reason, unless you ask us to. For example, if you see an ad for a nearby coffee shop and select the “tap to call” button, we’ll connect your call and share your phone number with the coffee shop.
• As described under the above sections “How we use the information we have collected” and “What are our information sharing practices”, we work with other services (such as AdMob) for advertising and ad measurement purposes. In order to help advertisers, decide what ads to show on Karta, Google, and websites & apps that partner with Google, Karta may share information with these services such as a unique identifier for advertising (Advertising ID available on Android mobile devices or similar technologies).
• The Ads personalization control described above apply to personalized ads served by Karta on the Karta Application and they do not apply to ads served on third parties’ platforms, including on Karta’s behalf.
• When you visit a third-party website from the Application, such third party may use cookies on your computer. The third party’s use of cookies is subject to their own privacy policies and not to this Privacy Policy. If you wish to study the privacy policies of those third parties you should visit their services, or contact them directly.

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.

• Data Transfers

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.

• Legal Requirements

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.

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 30^th, 2023

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.