Effective Date: October 08, 2026
HERE Global B.V., including its affiliates (“HERE”), is committed to respecting your privacy and complying with applicable data protection and privacy laws and regulations. HERE is the controller of your personal data for the processing described in this Notice. For more information about our privacy approach and full contact details, please visit our HERE Privacy Policy.
This Privacy Notice complements our HERE Privacy Policy and should be read together with it. Where this Notice refers to concepts already explained in said Policy (such as data subject rights, controller identity, international transfers, or security), the wording of the Policy applies
As part of product demonstrations, evaluations, and promotional initiatives, HERE may organize and record vehicle test drives. During these activities, video footage may be captured inside and outside the vehicle to demonstrate HERE product functionality in different driving scenarios.
In the above context, we are processing personal data to:
organize and conduct vehicle test drives and video creation activities, including protecting the safety and security of participants,
document, analyze, and demonstrate the functionality, performance, and user experience of HERE products and services as part of product development, validation, and training activities,
create marketing assets and content (including social media and website publications), internal and customer materials, and other communications relating to HERE products and services.
The recordings focus primarily on the operation of the vehicle in the driving environment but may incidentally capture pedestrians, cyclists, vehicles, license plates, and other objects. Any incidentally captured personal data is anonymized in post-production by irreversibly masking, editing, or blurring faces and license plates before further processing and use.
The legal basis for the processing of incidentally captured personal data of traffic participants and pedestrians is our legitimate interest in developing, improving, and promoting HERE products and services. We have conducted a legitimate interest assessment carefully weighing our interests against the potential impact on data subjects. This evaluation concluded that the rights of all individuals concerned are adequately safeguarded.
In cases where you actively participate in the recording activities e.g. as a model or driver, we secure an authorization to use your likeness in advance either in the form of a model release (contract between you and HERE) or a consent declaration, as may be applicable. HERE will provide additional details to the participants as necessary to ensure that either legal basis is valid, and your consent is freely given, specific, and informed.
The personal data processed under this Notice may relate to:
Traffic participants and pedestrians,
Drivers, passengers, and accompanying personnel,
Other individuals such as models who voluntarily participated in the recorded test drive activities.
Depending on the circumstances, the following categories of personal data may be processed:
Your likeness in video recordings,
Location and vehicle-related information data associated with the test drive including route and driving scenarios,
Any appearance of other vehicles, license plates, pedestrians, cyclists, or other traffic participants is incidental and unavoidable when filming public streets. Test drive routes are designed to avoid areas where accidental processing of special category data may occur; however, this cannot be entirely excluded. Measures are implemented to avoid such areas where feasible (e.g., private roads, military sensitive areas, hospital yards, religious centers).
We aim to collect only the personal data necessary for the stated purposes and retain it no longer than needed for those purposes. The retention period, and the criteria used to determine it, depend on the nature of the data and the purpose for which it was collected.
Video recordings and related production materials will generally be retained for as long as necessary to support the purposes described in this Notice, including product promotion, and documentation of business activities. Unblurred footage of license plates and faces of incidentally captured traffic participants is not retained beyond post-production activities, usually to be completed within a maximum of two months, depending on the length and complexity of the footage.
HERE may also retain certain data for the establishment, exercise, or defense of legal claims and to comply with legal, regulatory, accounting, or audit requirements.
We receive the above-mentioned personal data directly from you, including when you participate in a test drive or recording activity, appear in recorded footage, or communicate with HERE in connection with the activity.
We may share your personal data with the following categories of recipients:
HERE companies,
Authorized vendors including videographers, other media service providers, IT service providers who process personal data under the authority of HERE,
Customers, business partners, and prospective customers receiving demonstrations or presentations,
Public audiences where the resulting materials are published through websites, social media channels, events, conferences, exhibitions, or promotional campaigns,
Professional advisers, auditors, and legal consultants, as may be applicable.
Upon request, personal data may be provided to public authorities (e.g., to courts, police, or other law enforcement agencies) to the extent necessary and permitted by law.
Our products and services may be provided using resources and servers located in various countries around the world. Therefore, your personal data may be transferred across international borders outside the country where you use our services, including to countries outside the European Economic Area (EEA) or the United Kingdom that do not have laws providing specific protection for personal data or that have different legal rules on data protection, for example, the United States of America. In such cases we ensure that there is a legal basis for such a transfer and that adequate protection for your personal data is provided as required by applicable law, for example, by using standard contractual clauses approved by the European Commission or relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures. You may contact the HERE Privacy Office at privacy@HERE.com to obtain additional information about the safeguards we take in connection with these transfers.
During this personal data processing, automated decision-making based on the personal data does not occur.
During this personal data processing, profiling does not occur.
Depending on the circumstances of your case including your country of residence, you might have certain rights with respect to your personal data including:
Access,
Rectification,
Erasure,
Restriction of processing,
Objection,
Data portability,
Withdrawal of consent (with effect for the future),
Lodging a complaint with a competent authority.
To exercise your rights, please submit a request via:
https://www.here.com/en-gb/privacy/here-data-subject-request
Exercising your rights will not result in any adverse treatment.
For more information, please visit Your Rights section in our general Privacy Policy.
We prioritize privacy and security in our products and services by assigning dedicated responsibilities and enforcing internal policies, procedures, and controls designed to protect personal data. We implement appropriate technical and organizational measures to safeguard personal data against unauthorized access, disclosure, alteration, loss, and misuse, taking into account the nature of the processing and the risks involved.
Where recordings capture individuals incidentally in public environments, HERE will implement appropriate measures, such as editing, masking, or blurring.
For more information, please visit our Privacy Policy.
HERE may update this Notice from time to time.
Material changes will be communicated through a notice posted at the top of this document for at least 30 days.
