Statement About Petal Maps and Privacy
Last updated: February, 2022
Summary of the main changes introduced in this version of Petal Maps:
•Addition of Section 6 with information about child privacy.
•Adaptation of the statement to the iOS version of the service.
•Addition of the information about receiving comments about hotels from our partners to be displayed in the Map POI results. See Section 1.
•Changes to the address of the data controller.
Petal Maps is an app provided by Aspiegel SE, a subsidiary of Huawei in Ireland (hereinafter referred to as "Huawei", "we", "us", or "our") that provides map information, real-time traffic conditions, route planning, and navigation for traveling.
This Statement describes:
1 What Data Do We Collect About You?
3 How Long Do We Store Your Data?
5 What Are Your Rights and Options?
8 How Do We Update This Statement?
1 What Data Do We Collect About You?
As part of the Petal Maps, we shall collect and use your personal data only for the purposes stated in this Statement. Personal data refers to any information that enables us to identify you as a user.
We will collect and process the following data:
•HUAWEI ID account information: such as the account identifier, service token and the profile picture, which are processed by Petal Maps on the device.
•Location information: such as location data based on the GPS and network location (Wi-Fi and Cell ID) received on your device from your location services provider.
•Network information: such as IP address.
•Browser information (only when using the Petal Maps website): such as cookies (only essential cookies).
•Device information: such as device random identifier, device type, device name, ROM version, operating system version, and language.
•Service usage information (not all of the listed data here will be processed for the iOS version of the service as the features are limited there): such as frequently used addresses, search terms (name of the place, address, phone number, and longitude/latitude), search results (e.g. POIs), favorite places, start and end times of navigation, navigation routes, driving navigation information (longitude/latitude, language, and driving speed), traffic information, pictures provided when reviewing a place, comments and reviews made for places in the map, nearby bus stops, status of consent to marketing communication (switch on/off), search keywords and results (which will not be stored), and POI information contribution (such as correcting the address of a restaurant, or opening and closing hours of a business).
•Feedback information: such as device information, contact information (email address or phone number), and feedback description, including any attachments or logs you decide to add voluntarily.
•Campaigns participation information (not available in the iOS app version): such as home address and contact information provided when winning a prize, and campaign results.
•Third party related information that may not be related to Petal Map users: such as comments made about POIs on other platforms such as Booking.com. This data is only displayed on Petal Maps when users are searching for reviews on certain POIs (hotels, restaurants) without nickname or pictures.
If you are using Petal Maps on a Huawei device, you can sync your Petal Maps usage data to your cloud space. Your favorite places, frequently used addresses, and historical records of search and route planning will be synced and stored on HUAWEI Cloud. For more information about the data processing, you can go to Settings > HUAWEI ID > Cloud, touch the More options menu in the upper right corner of the screen, and go to About > Statement About HUAWEI Cloud and Privacy.
If you are a POI owner, please go here for more information on how the POI is processed.
To provide you with the service, Petal Maps needs to access the Internet and requires permissions to access Storage (when you upload files or images to Petal Maps), Camera (for taking pictures or videos to be uploaded), Location (for map information queries and navigation), and Microphone (for voice searches). If you are using the app on an iOS device, then only the Location permission is required. You can manage the permissions on your device from system Settings.
2 How Do We Use Your Data?
To provide you with the Petal Maps services and fulfill our contractual obligations, we need to collect and process your personal data so that you can search the map, plan routes, navigate, and save frequently used addresses. This also enables us to process your data for customer relationship management, support and communication, customer complaint handling, maintenance, software and system updates, user identification, and problem diagnosis and repair purposes.
In addition, we use your personal data for the following purposes based on legitimate interests:
•Analysis and development purposes. This enables us to understand your needs as customers and to improve the quality and user experience of our current and future services and offerings. This will include the processing of the fully anonymized location data and anonymized search input that will not link back to you, so we can improve the service that we provide to our users. You can object to such data processing as described in Section 5.6 below.
•Marketing purposes, including communicating about our offerings, sales promotion, and other marketing purposes, as well as creating aggregated target groups for marketing. You can object to such data processing as described in Section 5.6 below.
•Navigation improvement purposes (this feature is not available in the iOS app version). We will process your driving navigation data that contains the longitude/latitude, speed, and language, and the app ID of Petal Maps without any identifier that links to you directly or indirectly and without the location of your starting point and ending point for improvement purposes. This processing will help us understand the traffic and navigation in real time and correct the information available about routes and conditions. You can object to this processing at any time by going to Petal Maps > Me > Settings > Privacy management > Improve the map experience.
•Commute notification pushing purposes (this feature is not available in the iOS app version). When you have set your home or work address, set your commuting times, and agree to receive commute notifications, we will send you information about road and weather conditions before your commute times. You can disable notifications at any time by going to Petal Maps > Me > Settings > Commute settings.
•User contribution (this feature is not available in the iOS app version): We will process your HUAWEI ID and the POI information you contribute to Petal Maps via the app or website, for improving and rectifying the POI information in our service. The POI information may contain personal information of the owners of the businesses or places in the map (e.g. a pharmacy, restaurant, and doctor's office). If you are the owner of a store or other places identified by the POI information shared or rectified by Petal Maps end users, you can claim the POI or ask us to remove or rectify it by choosing your POI in the Petal Maps app, selecting Business Owner; then you will be provided with different choices such as removing the POI from the map or claiming the POI. For more information, please go here.
•Personalized recommendations (this feature is not available in the iOS app version): If you have the Petal Maps personalized recommendation feature enabled, your search history, terms, and results, approximate location, and HUAWEI ID information will be processed on your device only to provide you with search content tailored for you, displaying results such as restaurants and cafes that may be of interest to you based on your locally processed data. We only store the data on your device and will not transfer it to anywhere else. You can object to the personalization anytime by going to Petal Maps > Me > Settings > Privacy management > Personalized content on your device to disable this feature. Your search results will then be provided without any personalization and all the results will be shown to you only based on your search terms.
•Information security purposes, including processing your data to detect or prevent various types of misuse of services and fraud in order to provide you with secure and reliable services in all types of devices (Android and iOS).
•Campaign and fraud prevention purposes (these features are not available in the iOS app version): We also process your HUAWEI ID, IP address, and campaign information to prevent fraud when you take part in our campaigns/lucky draws to win prizes and claim them. Furthermore, your comments made and any content (e.g. pictures) you have provided when making reviews of places on the map or a contribution to a POI will be processed to ensure that such content is not unlawful and does not contain illegal or harmful information.
In addition, we use your personal data for the following purposes with your consent:
When you give consent, your location data will be processed to provide you with location based services such as navigation and positioning. You can withdraw your consent at any time by opening Petal Maps and going to Me > Settings > Privacy management > Location data consent.
Direct marketing purpose (this feature is not available in the iOS app version): When you are using Petal Maps while logged in with your HUAWEI ID, we may send you marketing communication via push notifications, emails, SMS messages, and instant messages to your device to inform you about new features, events, and offers from us and our partners, after you have given consent in the Petal Maps app. You can withdraw your consent at any time by going to Petal Maps > Me > Settings > Privacy management and disabling Notifications for the Petal Maps specific consent, and by going to Settings > HUAWEI ID > Privacy center > Receive messages on your device for the general consent.
If you are using the Petal Maps service in the visitor mode, we may send you marketing communication via push notifications to your device to inform you about new features, events, and offers from us and our partners, after you have given consent in the Petal Maps app. You can withdraw your consent at any time by going to Petal Maps > Me > Settings > Privacy management and disabling Notifications.
Incognito mode: If you are using the service in the incognito mode, your data will be processed to provide you with the service, but the search, route planning, and navigation records will not be retained on your device. Also, your data will not be processed for statistics or service improvement, nor for personalized recommendations.
3 How Long Do We Store Your Data?
We will retain your personal data for no longer than is necessary for the purposes defined in this Statement.
We will process and retain your data for the duration of the customer relationship.
However, we will retain:
•Personal data processed for customer relationship management such as complaints, data subject requests, and customer interactions for up to six (6) years from your last interaction with us.
•Personal data processed for statistical analysis and product development purposes for up to twelve (12) months from the date of collection, unless you object to such processing.
•Your home address and contact information processed to deliver the prizes won during campaigns for one (1) year from the time such data was provided. (Not applicable as the feature of campaigns and lucky draws is not available for the iOS version of the app)
•Feedback information processed to solve the issue and help improve the service to avoid similar bugs, for up to six (6) months from the date you provide it.
•Data backups and app logs processed to ensure the security of your data and services for up to six (6) months from the date of creation.
Once the retention period expires, we will delete or anonymize your personal data, unless otherwise required by applicable laws and regulations.
4 How Do We Share Your Data?
We store your data in the data centers located in the European Union (EU)/European Economic Area (EEA).
Our third-party vendors, who provide us with IT (including cloud-based) services and business support as well as customer care services, may need to process your information. All such third parties are operating under contract and acting on behalf of us, and are located in the EU/EEA. Unless you are using the service in the following countries:
•Canada, in which case we may share your personal data to customer service centers located in Mexico that are operated by our supplier operating under contract and acting on behalf of us.
•Australia or New Zealand, in which case we may share your personal data to customer support services located in Malaysia and Singapore, all operating under contract and acting on behalf of us.
We only share your data in the following circumstances:
•Your POI contributions will be disclosed to Huawei Services (Hong Kong) Co., Limited established in Hong Kong (China) for verification and synchronization purposes, without any HUAWEI ID account identifier or any other data that links directly to you, while the places like restaurants and stores contained in the contributions may be owned by individuals. This does not apply to the iOS version of the service as the user contribution feature is not available in iOS.
•When you sync your data to a third-party cloud storage provider, in which case your synced data will be disclosed to the cloud storage provider you chose with end-to-end encryption. Please ensure that you familiarize yourself with the third-party cloud storage provider's privacy policies on how they process your data. When syncing your data to a third-party cloud storage provider, your data may be transferred outside of the EU/EEA if the cloud storage provider is established outside of it. This does not apply to the iOS version of the service as the feature is not available in iOS.
•When you are using the "nearby" feature to check the bus stops available next to you, your location information (rough not precise) will be disclosed to our service provider for the public transportation related information HERE, established in the Netherlands. For more information about how HERE processes your data please refer to their privacy policy here. This does not apply to the iOS version of the service as the feature is not available in iOS.
•When accessing search results or detail pages through Bing results, your IP address, rough location (your city), and the search keywords (when looking for POIs) used will be shared to Bing, a Microsoft service to get the list of relevant results. Microsoft is established in Ireland and processes your data as a data controller according to its privacy policy, so please read it carefully. The same policy applies when you are visiting the links provided by Bing, and you will be in direct relationship with Microsoft (Petal Maps will not be involved). This does not apply to the iOS version of the service as the feature is not available in iOS.
•We may share your data in response to a legal process or request from a competent authority according to applicable laws or in connection with a legal proceeding or process.
•Your data may also be disclosed as part of a merger, acquisition, sale of assets (such as service agreements), or transfer of services to a Huawei group entity or another company.
When transferring and disclosing your data outside the EU/EEA, where the local law may not provide the same level of protection, we shall comply with applicable legal requirements for providing adequate safeguards to such transfers by incorporating the European Commission's Standard Contractual Clauses (SCC). If you want to obtain a copy of the actual signed SCC, please contact us.
5 What Are Your Rights and Options?
You do not have to log in with your HUAWEI ID to use Petal Maps, but are provided with the option to do so. The data that Petal Maps collects while you use the app, such as your HUAWEI ID account information, search history, locations used for navigation, and frequently used addresses, will only be stored locally on your phone.
You have the following data subject rights and options regarding your personal data:
5.1 Access your data
We process your Petal Maps data in a pseudonymized way and without linking such data with your HUAWEI ID or device identifier. If you want to get a copy of your data, please contact us.
You can request a copy and a description of the feedback you submitted by going to Me > HUAWEI ID > Privacy center > Request your data in the Petal Maps app.
For additional access requests, please contact us.
5.2 Rectify your data
To keep your data up to date and accurate, you can:
•Access and modify your frequently used addresses by going to Me > Favorites > Saved places in the Petal Maps app. This does not apply to the iOS version of the service as the feature of frequently used addresses is not available yet.
•Access and modify the data that you submitted on the Feedback screen by going to Me > Help > Feedback in the Petal Maps app.
5.3 Port your data
Data portability does not apply to your personal data in relation to Petal Maps, as it is not stored on the server.
However, you can port the data that you submitted on the Feedback screen by going to Me > HUAWEI ID > Privacy center > Request your data in the Petal Maps app.
5.4 Erase your data
You may at any time:
•Erase your frequently used addresses by going to Me > Favorites > Saved places in the Petal Maps app. This does not apply to the iOS version of the service as the feature of frequently used addresses is not available yet.
•Delete the content that you contributed by going to Me > My contributions in the Petal Maps app. This does not apply to the iOS version of the service as the user contribution feature is not available in iOS.
•Delete your comments made in Petal Maps by going to Me > My contributions > Reviews in the Petal Maps app. This does not apply to the iOS version of the service as the feature of comments is not available yet.
•Terminate your Petal Maps User Agreement by disabling the service. To do this, go to Me > Settings > Privacy management > DISABLE SERVICE.
•Delete your HUAWEI ID. This will erase your personal data linked with your HUAWEI ID including your personal data in relation to Petal Maps.
•Contact us if you think the processing of your personal data is unlawful and your data should be erased.
We will erase or anonymize your personal data without undue delay when necessary based on your aforementioned actions and in accordance with the retention periods as described in Section 3.
5.5 Withdraw your consent
If you have given your consent to the collection and processing of your data in order to get location-based services in Petal Maps during navigation, you can withdraw your consent by opening Petal Maps, going to Me > Settings > Privacy management > Location data consent.
If you have opted to receive electronic direct marketing from us and our partners, you can withdraw your consent by going to Me > Settings > Privacy management > Notifications in the Petal Maps app. This does not apply to the iOS version of the service as the feature is not available in iOS.
5.6 Object to processing
If you want to opt out from search content personalized recommendations, you can go to Petal Maps > Me > Settings > Privacy management > Personalized content on your device to disable this feature. This does not apply to the iOS version of the service as the feature of personalized recommendation is not available yet.
If you want to object to the processing of your data for marketing as well as analytics and development purposes, please contact us.
We will contact you to verify your identity in order to proceed with your request.
5.7 Restrict processing
You have the right to restrict the processing of your data in the following circumstances:
•Your data is unlawfully processed, but you do not want to erase it.
•You have a legal claim that you need to establish, exercise, or defend, and you have requested us to keep your data when we would not keep it otherwise.
•You have contested the accuracy of your personal data and the accuracy of your data is pending our verification.
•Your request for objection is pending our verification.
When making the request, we will contact you to verify your identity in order to proceed with your request.
6 How We Safeguard Children?
Children are allowed to use Petal Maps by logging in with their HUAWEI ID child account ("child account") created by their parent or guardian. When a user logs in with a child account, and as a result is identified as a child user, Petal Maps provides different safeguards to ensure age-appropriate data processing and content:
•In order to protect children from any harm caused by advertising, we do not use or allow others to use children as a specific target group for behavioral or other marketing activities. In addition, we never send electronic direct marketing messages to child account users.
•Personalized recommendation features, which include content personalization based on user's search and usage history, is not available to child accounts.
NOTE: If a child is using our services without being logged in with a child account, we are not capable of providing the child related safeguards provided by the service. We encourage all parents and guardians to create a child account for their child before they are allowed to start using any HMS apps or services. If a child is allowed to use Petal Maps without a child account, it is to be done under sole supervision of the parent or guardian.
7 How to Contact Us?
You can find guidance on how to exercise your data subject's rights in Section 5. If you have any questions, comments, or suggestions on your rights as a data subject or our processing of your personal data, or if you want to contact our Data Protection Officer, please contact us.
Our headquarters' address: Aspiegel SE, 3rd floor, Mespil Court, Mespil Road, Ballsbridge, Dublin 4, D04 E516, Ireland. Registration number 561134.
If you believe that we do not process your personal data in accordance with this Statement or the applicable data protection laws, you can lodge a complaint with the data protection authority in your country/region, or the Data Protection Commissioner in Ireland.
8 How Do We Update This Statement?
We encourage you to regularly check for the latest version of this Statement in the app settings as we may update it from time to time. In the event of material changes to this Statement, we will notify you in advance by means of notification dialogs, push messages, emails, and so on, depending on the nature of the change.