Waze states that once your data is combined with others and stripped of identifying details, it is no longer considered personal information under this policy and can be shared with any party for any purpose without restriction.
This analysis describes what Waze's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision asserts a broad carve-out from the policy's privacy protections for aggregated or de-identified data, and does not specify a standard for what constitutes adequate de-identification or describe safeguards against re-identification.
Interpretive note: The policy does not specify the de-identification standard applied; under GDPR, data that Waze treats as anonymous may still constitute personal data if re-identification is reasonably possible, meaning the practical scope of this carve-out is legally uncertain in EU/EEA jurisdictions.
The updated policy now explicitly discloses that Waze periodically collects all phone numbers stored on your device's contact book as part of the 'find friends' feature. According to the revised terms, these phone numbers are collected in a form that is initially anonymous to Waze and are used to help create a list of other Waze users you may know. The policy clarifies that names, addresses, and other contact information are not collected from your phone book, though such information may be saved locally on your device for local searches. Additionally, the updated terms now explicitly authorize connecting your Waze account to social network accounts and sharing profile information from those networks. You can control whether to use the 'find friends' feature and whether to connect social network accounts to your Waze account.
View change record →The updated policy removes explicit language describing how Waze collects phone numbers from device contact books and integrates social network accounts. Previously, the policy stated that Waze would 'periodically collect all of the phone numbers which are stored on your device's phone contacts book' and described how this information was used for the 'find friends' feature. The revised policy no longer includes these specific disclosures. This does not necessarily mean the practices have stopped, but it means the policy provides less transparency about what data Waze collects from your device and how it uses contact information. Users who relied on these detailed descriptions to understand Waze's data practices will find the updated policy less explicit on these points.
View change record →The updated privacy policy now explicitly discloses that Waze periodically collects all phone numbers stored in your device's contact book as part of the 'find friends' feature. According to the policy, this information is collected in an anonymous form to Waze and is used to identify other Waze users you may know. The terms also clarify that social network information can be shared with Waze and other users if you choose to connect your social network account. While the policy states that names, addresses, and other contact book information are not collected, some contact information may be saved locally on your device for local search purposes. You can control whether this feature operates by not using the 'find friends' feature or by not granting the app contact access through your device settings.
View change record →The policy states that data Waze determines to be aggregated or de-identified falls outside the scope of its privacy commitments and can be shared without restriction; the practical scope of this carve-out depends on the de-identification standard applied, which the policy does not specify.
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At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
We use information to enhance the quality, reliability, and/or accuracy of our AI Features by creating, developing, training, testing, improving, and maintaining AI and ML models run by Strava or our service providers. We use aggregated, de-identified data for this purpose. We also use personal info...
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"We may use aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you for any purpose, including sharing it with partners, advertisers, and other third parties. This information is not subject to the restrictions in this Privacy Policy.— Excerpt from Waze's Waze Privacy Policy
1) REGULATORY LANDSCAPE: GDPR does not exempt truly anonymous data from its scope, but the determination of whether data is genuinely anonymized (rather than merely pseudonymized) requires a high standard under the Article 29 Working Party and EDPB guidance; pseudonymized data remains personal data under GDPR. CCPA similarly provides a de-identification exception but requires companies to implement technical safeguards and contractual prohibitions on re-identification. The FTC has issued guidance cautioning that aggregation does not guarantee anonymization given re-identification research. 2) GOVERNANCE EXPOSURE: Medium. The provision's assertion that de-identified data is unrestricted is consistent with common industry practice but may overstate the legal position under GDPR, where the adequacy of anonymization is assessed contextually and regulatory guidance sets a high bar. Compliance teams should verify that the de-identification standard applied by Waze meets the EDPB's anonymization criteria and the CCPA's technical safeguard requirements. 3) JURISDICTION FLAGS: EU/EEA jurisdictions present the highest exposure given GDPR's strict anonymization standard; data that Waze treats as anonymous may still constitute personal data under GDPR if re-identification is reasonably possible given available means. California's CPRA maintains CCPA de-identification requirements including contractual prohibitions on downstream re-identification. 4) CONTRACT AND VENDOR IMPLICATIONS: Contracts with partners receiving de-identified data should include explicit prohibitions on re-identification consistent with CCPA requirements. Data processing agreements should specify the de-identification methodology applied. 5) COMPLIANCE CONSIDERATIONS: Legal teams should document the specific de-identification methodology used and assess it against EDPB anonymization guidance and CCPA technical safeguard standards. Periodic re-identification risk assessments should be conducted, particularly given the sensitivity of the underlying location and behavioral data.
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This provision asserts a broad carve-out from the policy's privacy protections for aggregated or de-identified data, and does not specify a standard for what constitutes adequate de-identification or describe safeguards against re-identification.
The policy states that data Waze determines to be aggregated or de-identified falls outside the scope of its privacy commitments and can be shared without restriction; the practical scope of this carve-out depends on the de-identification standard applied, which the policy does not specify.
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