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TomTom Maps

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TomTom Maps provides interactive maps, geocoding and routing through a JavaScript SDK and Maps API. Loading a map sends the visitor IP address to TomTom and may use local storage or cookies, while location features process the visitor position, so consent is generally required.

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Overview

What does TomTom Maps do?

What TomTom Maps is

TomTom Maps is a mapping platform that lets websites embed interactive maps and use services such as geocoding, search and routing. Developers add the TomTom Maps SDK or call the Maps API, and the browser then loads map tiles and runs the SDK. It is a common alternative to other commercial map providers and is often chosen by EU businesses because TomTom is based in the Netherlands.

What data and cookies it collects

Whenever a map loads, the visitor browser contacts TomTom servers, which receive the IP address, the requested map area and technical request data. The SDK may store data in the browser local storage for caching and can set cookies. If you use geolocation features, the visitor approximate or precise position is processed as well. The IP address and any location data are personal data under the GDPR.

GDPR and ePrivacy implications

Storing or reading data on the visitor device through cookies or local storage that is not strictly necessary triggers Article 5(3) of the ePrivacy Directive and the need for consent. Processing the IP address and any geolocation is governed by the GDPR. Because an embedded map is rarely strictly necessary, you should treat it as a non essential feature that requires a lawful basis before it loads.

Consent requirements

Use of precise geolocation always requires explicit consent, and the browser itself will prompt the visitor before sharing the position. For the map embed, the safest approach is to load it only after the visitor accepts, or to use a click to load placeholder so that no data goes to TomTom until the visitor chooses to view the map. Consent must be recorded and revocable.

Data transfers

TomTom is a Netherlands based company, which keeps a large part of processing within the EU and is generally favourable for European users. Even so, tile and API delivery can run through a global content delivery network, so some edge processing may occur outside the EEA. Review your TomTom agreement to confirm the data location and the safeguards that apply, and disclose any transfer in your privacy notice.

Practical compliance steps

Place the map behind your consent management platform or a click to load wrapper, request geolocation only when the visitor asks for it, and sign a data processing agreement with TomTom. List the map cookies and local storage in your cookie policy, explain the purpose of any location processing, and keep a record of consent. Review the transfer position periodically as the service evolves.

Compliance

TomTom Maps and the GDPR

TomTom Maps is classified as “Preferences”. On a site that targets European visitors, it must only load after the visitor consents, and it must be listed in your cookie policy.

Legal basis
Consent under Article 6(1)(a) GDPR for precise geolocation and for any non essential cookies, with Article 5(3) ePrivacy applying to device storage
Risk level
medium
Applicable regulations
GDPR, ePrivacy Directive

Impact assessment (DPIA)

A DPIA is advisable where precise geolocation is used at scale or where map interactions are combined with other profiling, as location is sensitive context data. For a simple embedded map a documented assessment of the IP processing, the use of geolocation and the delivery network is usually sufficient. The EU base of TomTom reduces, but does not remove, the transfer risk.

Sample text for your banner

This page can display an interactive TomTom map. Loading it sends your IP address to TomTom and may use your location. Do you consent to load the map and, where used, share your location?
Cookies and trackers

What TomTom Maps sets and contacts

Tracking method
JavaScript SDK and Maps API calls that load tiles and may use local storage and cookies, processing IP address and location
Server location
Netherlands and European Union, with global content delivery
Data transferred outside the EU
TomTom is headquartered in the Netherlands and processes much data within the EU, which is favourable for EU users. However API and tile requests can be served through a global content delivery network, so some routing or edge processing may occur outside the EEA. Confirm the current data location and any safeguards in your TomTom agreement.

Cookies set (2)

NameTypeDurationPurpose
TomTom SDK local storageFunctionalPersistent until clearedThe Maps SDK stores tile and configuration data in browser local storage to cache map content and improve loading performance.
tomtom_sessionFunctionalSessionMay be set to associate map and API requests within a single session for rate limiting and service operation.

Third-party domains contacted (3)

  • api.tomtom.com
  • kr1.api.tomtom.com
  • www.tomtom.com
Questions

Frequently asked questions about TomTom Maps

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What cookies does TomTom Maps set?

The Maps SDK mainly uses browser local storage to cache tiles and configuration, and it may set functional cookies for session handling and rate limiting. These are not strictly necessary for your site, so they generally require consent.

Do I need consent to use TomTom Maps?

Yes, in most cases. Loading the map sends the visitor IP to TomTom and uses non essential storage, and any precise geolocation needs explicit consent, so you should load the map only after the visitor agrees.

What is the legal basis for processing?

The legal basis is consent under Article 6(1)(a) GDPR for precise location and for non essential storage, with Article 5(3) ePrivacy governing the cookies and local storage placed on the device.

Does TomTom transfer data to the US?

TomTom is based in the Netherlands and keeps much processing in the EU, which is favourable. However tiles and API responses can be served through a global delivery network, so some edge processing may occur outside the EEA. Confirm the data location in your TomTom agreement.

Is a DPIA needed for TomTom Maps?

A DPIA is advisable when precise geolocation is used at scale or combined with other profiling. For a simple embedded map a documented assessment of IP processing, location use and delivery is usually enough.

How do I implement TomTom Maps compliantly?

Use a click to load placeholder or block the map behind consent, request geolocation only on user action, sign a data processing agreement, and list the cookies and local storage in your cookie policy with a clear purpose.

Are there alternatives to TomTom Maps?

Yes. OpenLayers or Leaflet with self hosted or OpenStreetMap tiles can reduce third party data sharing, and other EU based map providers exist. The right choice depends on your need for routing, search and styling.

How should I update my cookie policy?

State that the page embeds TomTom Maps, list the local storage and cookies it uses with their purpose, name TomTom as the recipient, and explain that loading the map sends your IP and that location may be processed with consent.

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