ADAS Vehicle Public Filming Data Privacy Notice

 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 Testing Vehicle owned by the Respective Client 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. 

Ubiquity Service sp. Z o.o. is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.

Our contact details are as follows:

Ubiquity Service Sp. z o.o.

Postępu 21A, 02-676 Warszawa, Polska 

Phone number: +48 881 658 866

Email: biz@ubiqservice.com

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, 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.

 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 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.

We collect personal data, including video footage and images, and keep it before anonymization no longer than necessary , with a max term  of 6 months. The original data is fully anonymized and subsequently utilized exclusively for the purpose of vehicle software updates.

 In order to provide safe and compliant storage solutions, we use Alibaba Cloud Object Storage Service (OSS) with servers located in Frankfurt, Germany.

Below are the security and compliance documents of this product:

(1) https://www.alibabacloud.com/help/en/oss/security-and-compliance/overview-11

(2) https://www.alibabacloud.com/en/trust-center/compliance?_p_lc=1&spm=a3c0i.15008052.5413286670.4.3ca561e8nnfLGe#J_5959942230

Alibaba OSS data encryption document: https://www.alibabacloud.com/help/en/oss/security-and-compliance/data-encryption-2?spm=a2c63.p38356.0.i3#concept-2538602

The provider is Alibaba (Netherlands) B.V. a company incorporated under the laws of Netherlands and having its registered address at Herengracht 448, 1017CA Amsterdam. 

Further information on privacy  and product terms in connection with Alibaba OSS service is available here: https://www.alibabacloud.com/help/en/legal/latest/alibaba-cloud-international-website-product-terms-of-service-v-3-8-0?spm=a2c63.p38356.help-menu-42384.d_0_0.12515f9bKzmqFG&scm=20140722.H_42416._.OR_help-T_intl~en-V_1

Personal data collected and processed by the Company is not transferred outside the European Union (EU) and UK.

For transfers  of the data collected in UK between the United Kingdom (UK) to the European Economic Area (EEA), personal data may be transferred from the UK to the EEA based on Standard Contractual Clauses (SCCs) established between the UK legal entity and the corresponding Polish-based legal entity, ensuring compliance with applicable data protection laws and safeguarding the rights and freedoms of data subjects.

You are entitled to receive an overview of third country recipients and a copy of the specifically agreed provisions securing an appropriate level of data protection. For this purpose, please use the statements made in the “Contact” section (see no. 10).

 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. All video footage and related images will be deleted within six months of collection.

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. We use encryption at every step of data collection and processing.

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 Ubiquity Service personnel.

 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 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 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, including withdrawing consent, please visit this web form and complete the required fields at the bottom of this page or contact us using the details provided in Section 2 of this document.

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.

You have the right to lodge a complaint with a supervisory authority. You can appeal to the supervisory authority which is responsible for your place of residence or your state of residency or to the supervisory authority responsible for us. 

EU Supervising Authority:Office of the President for Personal Data Protection
Urzad Ochrony Danych OsobowychStawki 2
00-193 Warsaw
Poland

Tel. +48 22 531 03 00
Fax +48 22 243 05 69
https://uodo.gov.pl/
kancelaria@uodo.gov.pl

UK  Supervising Authority: Information Commissioner’s Office
Wycliffe House
Water Lane
Cheshire SK9 5AF
Tel: 0303 123 1113 or 01625 545 745

https://ico.org.uk/make-a-complaint/https://ico.org.ukThe ICO has also regional offices in Edinburgh, Cardiff and Belfas

 We reserve the right to change our security and data protection measures. In such cases, we will amend our data protection notice accordingly. Please, therefore, notice the current version of our data protection notice, as this is subject to changes. 

  If you wish to contact us, please find us at the address stated in the “Controller” section (see no. 2) or use the form at the bottom of this page. 

Last Updated: 13.02.2024

Effective Date: February 01, 2023