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ADAS Vehicle Public Filming Data Privacy Notice

1. PURPOSE OF THIS NOTICE AND OVERVIEW

Ubiqservice holds a deep respect for your privacy and is fully committed to safeguarding it. This ADAS Vehicle Public Filming Data Privacy Notice ("Notice") aims to provide you with information on how we handle your personal data in our capacity as a data controller under applicable data privacy laws. This processing occurs when we record live video footage, images, and signals through [Vehicle Type] owned by [Customer Name], to enhance our Advanced Driver Assistance System (ADAS) and improve the safety features of our vehicles to promote road safety. In this document, the terms "we," "us," or "our" refer to the Ubiqservice entity responsible for collecting and utilizing personal data obtained via the vehicle's cameras. For additional details, please refer to the "Contact Us" section below.

Ubiqservice firmly believes in a more responsible approach to exploring the world, including our commitment to enhancing road safety for all road users. As part of our mission to develop features that improve pedestrian and road safety, our vehicles may collect your personal data. As we will elaborate further below, Ubiqservice test vehicles are equipped with cameras that capture road markings, signage, and other public elements and areas visible from or accessible by the vehicles. We may utilize this footage to enhance our vehicles' capabilities for ADAS-related features and improve safety features, contributing to enhanced road safety.

2. CATEGORIES OF PERSONAL DATA WE COLLECT

In the case of specific test vehicles, we might gather and process sensor data, vehicle location information, and external video and camera imagery from external vehicle cameras. Below, we provide a more detailed overview of each of these data types.

Location Data: We may collect and process location data, such as GPS coordinates, to determine the vehicle's precise location. This data is instrumental in supporting our various features.

External Vehicle Cameras: Our external cameras are employed to capture video footage and images of the vehicle's surrounding environment. This information is crucial for ensuring the safe operation of our features and for enhancing our existing ADAS algorithms and image recognition (AI). This includes the recognition of road markings, signage, and other visual elements. Additionally, our cameras may capture the location, video footage, and images of individuals in proximity to the vehicles. Moreover, the cameras may record license plates of other vehicles or other publicly visible personal details. It is important to note that we do not make any attempts to link external video and camera data with identifiable individuals or vehicles, except when compelled to do so by law or for the purposes of a collision investigation.

3. PURPOSES AND LEGAL GROUNDS FOR WHICH RIVIAN COLLECTS AND USES YOUR PERSONAL DATA

We gather and process the data detailed in Section 2 for the following objectives:

  • Enhancing and refining our existing ADAS algorithms and image recognition (AI), with a focus on recognizing road markings and signage, aimed at enhancing road safety and reducing the risk of traffic accidents.
  • Enhancing vehicle safety features, encompassing collision avoidance brake assistance, lane-keeping assistance, and distance-keeping features.
  • Pioneering new automated driving functionalities and advanced driver assistance systems.
  • Creating maps and other country-specific driver assistance safety features.
  • For the purposes described above, any test vehicles employed will be conspicuously marked, typically featuring our company logo, a dedicated website URL, and a QR code allowing access to this Notice.

The processing of the data outlined in Section 2 is necessary for pursuing the legitimate interests of Ubiqservice. In line with Art. 6(1)(f) of the European Union General Data Protection Regulation, we have undertaken an evaluation to ensure that the processing is proportionate and does not unduly infringe upon the rights and interests of individuals captured, including children.

4. CROSS-BORDER DATA TRANSFERS

We may transfer your personal data to or store it in European countries, including countries that may not have data protection laws equivalent to those in your country of residence or the location where your personal data is gathered. This transfer is conducted for the purposes outlined earlier. For example, we might share the captured footage with Ubiqservice teams and third parties we've contracted with to assist in annotating and analyzing the images for the mentioned processing tasks.

In cases of data transfers from European Economic Area ("EEA") Member States or the UK to countries that have received an adequacy decision from the European Union ("EU") Commission or the United Kingdom ("UK") Information Commissioner’s Office, confirming that their data protection standards are on par with those of the EU or UK, we can rely on these adequacy decisions. This particularly applies to data transfers between the UK and EEA Member States.

For data transfers from the EEA or UK to countries lacking an adequacy decision, Ubiqservice has established appropriate safeguards to ensure the necessary level of data protection. This is primarily achieved through the implementation of suitable data transfer arrangements based on approved standard contractual clauses.

5. DATA RETENTION AND SECURITY

To safeguard the rights and freedoms of individuals, we employ the following measures during the aforementioned processing activities and subsequently erase the footage when it is no longer required. The majority of video footage and related images will be deleted within six months of collection. A small portion of video and images may be retained for a longer duration only as necessary for enhancing object detection algorithms.

We have instituted appropriate technical and organizational safeguards to secure the collected data against loss, tampering, unauthorized access, disclosure, as well as accidental or unlawful destruction.

Before being transferred to the cloud, the video footage is temporarily stored on encrypted data storage drives. Access to this data is restricted to authorized Ubiqservice personnel and trusted third parties involved in the annotation and analysis, as mentioned earlier.

6. YOUR DATA PRIVACY RIGHTS

Depending on your location and the applicable laws and regulations, you may possess data privacy rights concerning Ubiqservice's handling of your personal data. In accordance with the legal requirements specific to your jurisdiction, and subject to any legal restrictions or exceptions, you may enjoy the following rights:

  • Access/Know: Request confirmation from us regarding whether we are processing your personal data and, if so, obtain access to such data and/or detailed information about the data processing.
  • Deletion/Erasure: Request the prompt deletion of your personal data. There may be situations where we cannot accommodate your request, such as when processing is required to comply with a legal obligation or for the performance of a contract.
  • Restriction of Processing: Request that we limit the processing of your personal data. Again, there may be cases where we cannot fulfill your request, for instance, if the processing is necessary to meet a legal obligation or if we can demonstrate compelling legitimate grounds to the contrary.
  • Object to Processing: Object to the processing of your personal data on grounds related to your specific situation, in cases where it is (i) necessary for the performance of a task carried out in the public interest, (ii) carried out in the exercise of official authority vested in us, or (iii) based on our legitimate interests. In such cases, unless we can demonstrate compelling legitimate reasons for processing that override your interests, rights, and freedoms or the processing is required to assert, exercise, or defend legal claims, we will generally cease processing the personal data.
  • Complaints: You may file a complaint with a supervisory authority if you believe that the processing of your personal data violates applicable law. If your complaint pertains to provisions of the EU GDPR, you can direct it to a supervisory authority in your place of residence, work, or the location of the alleged infringement. The lead supervisory authority can be identified based on your location through the European Data Protection Board website. If the complaint relates to provisions of the UK GDPR, you can file it with the Information Commissioner's Office.

To exercise your privacy rights, please visit this web form.

We will acknowledge and address these requests as promptly as possible. Initially, we will respond to and fulfill such requests within one month, or in accordance with applicable laws, which may extend to a slightly longer period. In cases where we are unable to comply with a request or unable to fulfill it within that timeframe, we will generally provide you with an explanation. We may request specific information from you to confirm your identity and rights. Applicable laws may authorize or necessitate us to decline access to some or all of the personal data we hold about you, or we may have deleted, erased, or anonymized your personal data in compliance with our record retention obligations and practices. If we are unable to grant you access to your personal data, we will typically explain the reasons for this, subject to any legal or regulatory constraints.

We will not engage in any discriminatory practices against you for exercising your privacy rights.

7. CHANGES TO THIS NOTICE

We reserve the right to update this Notice at any time, and we will post the new Notice as soon as possible.

Last Updated: May 10, 2024
Effective Date: February 01, 2023

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