1. Information We Collect
- Account Information: If you sign up for or authenticate into an account with us, we may collect information that you provide to us in connection with setting up the account, such as your username, name, email address and, for an account you authenticate into, role. Further, in the course of using your account, you may provide us with additional information through your communications with us.
- Payment Information: Payment is required for some of our Services, and we may ask you to provide certain information, including your name, address, email, and credit card information (collectively, “Payment Information”), in connection with processing your transactions. You may update your Payment Information through your account.
- Information from Our Vendors: We may receive information related to your use of our Vendor websites and services, including your username, name, email address, shipping address and your interaction with our Vendor. Common examples include signing up for an event or requesting shipment of a product from us.
- APIs and Mobile SDKs: We automatically collect certain technical information whenever requests are made to our APIs, including (a) IP address, (b) device and browser information, (c) operating system, (d) the content of the request, (e) the date and time of the request, and (f) limited location and usage data. We delete IP addresses after 30 days. In addition, when a mobile application uses our SDKs to access our APIs, it may send us certain limited location and usage data along with an ephemeral ID. We delete this ephemeral ID within 24 hours and do not associate it or the unprocessed mobile location data with any personally identifying information, including names, permanent IDs, email addresses, IP addresses, or phone numbers. We also collect randomly-generated IDs for the limited purpose of analyzing the use of our APIs, including the number of active users. We will delete the randomly generated IDs and the content of requests made to our APIs after 36 months.
- AI Dashcam SDK: We automatically collect certain information whenever the AI Dashcam SDK is in use, including (a) IP address, (b) device and browser information, (c) operating system, (d) the content of the API requests, (e) the date and time of the request, (f) limited location and usage data, (g) limited front-facing camera imagery and video, (h) a randomly generated ID, (i) accelerometer data and (j) detected road feature data.
- Hosted Data: In using your account, you may upload data to us via General Magic Studio, or our API’s (“Hosted Data”) so that General Magic can host it for you as part of providing our Services. We delete Hosted Data upon your request, however, due to our highly available, distributed implementation of our hosting solution, artifacts of Hosted Data may remain on General Magic systems after you delete the file in your account. We will delete those artifacts in accordance with our standard platform maintenance practices after we either receive a specific request from you to delete the Hosted Data artifacts (along with sufficient information to identify which data you want to ensure are deleted) or we receive a request from you to delete your account.
- Feedback: You and/or your end users may provide us with feedback regarding our Services (e.g., in the form of email, suggestions for how to improve our maps, etc). We do not delete this information.
2. How We Use the Information We Collect
- Account Information: We use the account information we collect to provide our Services to you, to maintain your accounts, and to process your transactions. This information is necessary for us to provide the Services to you. We may combine account information with data we receive from other sources. We also may use certain information, such as your email address, to help you by telling you about new General Magic products or features that may be of interest to you and by providing you with examples of how General Magic products and services can be used. We have a legitimate interest in improving and marketing our Services. If you receive promotional emails from General Magic, you can opt out by following the instructions in those emails.
- Payment Information: We use payment information solely for billing purposes, which is necessary to provide the Services.
- Information from Our Vendors: We may use the information you provide to our Vendors in connection with the event or transaction (including shipments and deliveries), to improve our Services, and to provide you with information about our Services and/or the event or transaction. We have a legitimate interest in improving and marketing our Services and certain data collection is necessary in order to provide the Services. You may opt out of receiving promotional communications from us at any time.
- APIs and Mobile SDKs: We use the data collected through our APIs and SDKs (1) for internal diagnostic and analytic purposes (2) to improve our mapping products and services (3) to provide our Services to end users of our customers and (4) to generate aggregated and anonymized usage statistics. We have a legitimate interest in improving our Services and certain data collection is necessary in order to provide the Services. You can find more information specifically about how we secure and use location data on our telemetry page.
- AI Dashcam SDK: We use the data collected from AI Dashcam SDK (a) for internal diagnostic and analytic purposes, (b) to improve our mapping products and services, (c) to provide our Services to end users of our customers and (d) to generate aggregated and anonymized usage statistics. We have a legitimate interest in improving our Services and certain data collection is necessary in order to provide the Services.
- Hosted Data: We use Hosted Data to provide our Services to you.
- Feedback: We may use the feedback that you provide for any purpose, including improving our Services. We have a legitimate interest in improving our Services for the benefit of all of our users.
3. When We Share the Information We Collect With Third Parties
- In General:We are a global company and may transfer your information outside of the country where you live. However, we will not transfer personal information outside of the European Union unless the recipient complies with the Privacy Shield Principles (see “S.-EU Privacy Shield and Swiss-U.S. Privacy Shield” below) or is subject to suitable contractual safeguards to ensure that the personal information is processed in accordance with EU law. For more information, please email us at email@example.com.
- Account Information and Information from our Vendors: We may share your account information and information we receive from our Vendors with our Vendors and other service providers who need access to such information to carry out work on our behalf.
- Payment Information: We may disclose Payment Information to (a) our payment provider, Stripe, as described above in the “Information We Collect” section, (b) billing and accounting service providers acting on our behalf and (c) in connection with “Rare and Limited Disclosures” described below.
- Website Logs and Cookies: We may share information about your device and interaction with our website with our service providers that host our website and provide marketing and analytics services to us. These third parties that we may use may collect information about your device and interaction with our websites (including by using cookies and similar technologies). We do not control how these third parties use or share this information, which is subject to their privacy policies.
- APIs and Mobile SDKs: We only share raw location data with our hosted infrastructure service providers. We share other data collected through your use of our APIs and SDKs with our hosted infrastructure and internal analytics service providers. In limited situations, we may also share API log data associated with a specific customer’s account with that customer for the purpose of resolving billing questions. We also may share aggregated and anonymized usage statistics with other third parties.
- AI Dashcam SDK: We share data collected through your use of AI Dashcam SDK with our hosted infrastructure and internal analytics service providers. In addition, we may share AI Dashcam SDK data with the person or entity that controls the account associated with the data. We also may share aggregated and anonymized usage statistics with other third parties.
- Feedback: We may share your feedback with third parties, including our third-party suppliers and partners who help us provide the Services.
- Rare and Limited Disclosures: We may share information in our possession in response to a request if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process. For more information, see “Law Enforcement and Transparency,” below.
- Furthermore, we may share information in our possession if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to enforce our terms of service, detect, prevent, or otherwise address threats to our platform, or protect against harm to the rights, property or safety of General Magic, our users, or the public as required or permitted by law.
- Finally, we may also share the information we collect in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company. We may also share information among our current and future parents, affiliates, subsidiaries and other companies under common control and ownership.
4. Your Choices About What We Do With the Information We Collect
- Account and Payment Information: Certain account information is optional, and you may choose not to provide it to General Magic. Note that some of this account and payment information is necessary for related Services to function properly – for example, if you do not provide payment information, you cannot take advantage of features that require payment.
- Website Logs and Cookies: You may delete cookies from your computer, and most browsers provide the option to block cookies. Note that if you block cookies placed by us (first party cookies), portions of our Services, including our website, may not work as intended. However, your access to our websites should not be affected if you disable third-party cookies placed by third parties that manage marketing and analytics aspects of our website.
- APIs and Mobile SDKs: If you are an end user of a product or service that integrates our Services, your privacy options will be largely determined by the developer of the product or service. In addition to any privacy options that the developer may have provided you with, you may also be able to control the applications that can collect information about your precise location by using the settings available on your device.
5. Your Access to and Control of the Information We Collect
- Account Information, Hosted Data, and Payment Information: You may correct or change certain account information in the account pages we’ve made available to you, and you may update, correct or delete other Account Information, Hosted Data or Payment Information that you have provided to us at any time by emailing us at firstname.lastname@example.org. If you wish to delete or deactivate your account, please email us at email@example.com, but note that we may retain certain information as required by law or to protect our rights and property.
- Website Logs, Cookies, APIs and Mobile SDKs: We temporarily retain IP addresses for security and accounting purposes. Given the temporary nature of this storage, it is generally not feasible for us to provide access to IP addresses or the logs associated with them.
- Feedback: You may request that we update, correct or delete any feedback that you have provided to us by emailing us at firstname.lastname@example.org, however we may have deleted or anonymized the feedback you had previously provided to us in a way that makes it infeasible for us to associate a particular piece of feedback with a particular user.
6. Law Enforcement and Transparency
- In General:Although we acknowledge that government sometimes must act to protect citizens’ safety and security, we strongly believe that current laws regulating surveillance of individuals and access to user information need to be reformed.
- We post anonymized information about all law enforcement requests in our transparency report. General Magic has never received a national security letter, FISA court order, or any other classified request for user information. If we ever receive such a request, we will review it carefully and make sure it follows the law (including the Fourth Amendment). If we believe a request is overly broad, we will seek to narrow it.
- If we have a good faith belief that there is an emergency involving the danger of death or severe physical injury, we may disclose limited information necessary to prevent that harm.
- Account Information, Hosted Data, Store Data and Payment Information: We require a subpoena or court order to provide information about your account, such as the name associated with the account, means of payment, and length of service. If we are ever forced to share identifiable information about you, we’ll notify you with the full details of the request before we disclose it unless we are legally prohibited from doing so by law or court order.
- Website Logs, Cookies, APIs and Mobile SDKs: We will only disclose information collected through our Services, including maps and associated data and location information, in response to a subpoena or court order.
7. S.-EU Privacy Shield and Swiss-U.S. Privacy Shield
- In compliance with the Privacy Shield Principles, we are committed to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us using the information in the “Contact Us” section below. We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.
- Under certain conditions, you may be able to invoke binding arbitration to resolve your complaint. General Magic is subject to the investigatory and enforcement powers of the Federal Trade Commission.
- If we share personal data transferred to the U.S. under the Privacy Shield with a third-party service provider that processes such data on our behalf, then we will be liable for that third party’s processing in violation of the U.S. Privacy Shield Principles, unless we can prove that we are not responsible for the event giving rise to the damage.