I live in this world, data privacy, data governance and cyber security. Trust me, with the FCC, SEC, FTC, California Privacy law and many other states, one does not muck around with public statements that are not truthful around data usage. That is why so many are getting "privacy update" notices.
I would say that TomTom actually uses the location data in a fairly scrupulous manner, and then deletes it. Far different that GMaps, Waze, etc. or any other "free" consumer app (look at what TikTok does on a phone, it will make you shudder).