This Test Vehicles Privacy Notice describes how we, MicroVision GmbH (“MicroVision”), Neuer Höltigbaum 6, 22143 Hamburg, Germany, use and otherwise process personal data that we collected by cameras on our test vehicles, as well as rights you may have with respect to your personal data.
What personal data do we collect?
MicroVision collects measurement and video data on our test vehicles. The video data also includes the license plates of other vehicles, and under certain circumstances, the faces of persons if they are in the immediate vicinity of the recording vehicles (pedestrians and cyclists as well as occupants of other vehicles).
For what purposes do we process your personal data and on what lawful bases?
The purpose of the camera data collection is to test MicroVision's own lidar sensors under real conditions, for example in real road traffic, in order to ensure product safety and to continuously develop the products according to the state of the art. For the accuracy of the results, a clear recording is necessary, which provides a complete overview of the traffic situation. We have no interest in identifying an individual person and our systems are not configured for such means, as this is not necessary for the above purpose.
The legal basis for the processing is Article 6 (1)(f) of the EU General Data Protection Regulation (GDPR).
To whom do we disclose your personal data?
We only disclose personal data as follows:
- To our parent company: In some cases, it is necessary to share your personal data with our parent company, MicroVision, Inc. in the United States. MicroVision, Inc.’s address is 18390 NE 68th St, Redmond WA, USA 98052, and its EU DPO is Thorsten Ihler (firstname.lastname@example.org). As our parent company, MicroVision, Inc. is also involved in the development of MicroVision’s lidar sensors and to ensure its safety performance. MicroVision, Inc. processes your personal data for the same purposes as those set forth in this privacy notice and on the basis of the same lawful bases of processing. Access to your personal data is provided to MicroVision, Inc. only on a need-to-know-basis.
- Third-party service providers: Certain third-party service providers will receive your personal data to process such data under appropriate instructions as necessary for the processing purposes, in particular to carry out certain data labeling tasks (e.g., identifying recorded objects and/or differentiating between multiple vehicles or pedestrians etc.) These service providers will be subjected to contractual obligations to implement appropriate technical and organizational security measures to safeguard your personal data, and to process your personal data only as instructed.
Where is your personal data processed and on what basis do we transfer personal data across borders?
We disclose your personal data to our parent company, MicroVision, Inc. in the United States. We take measures to ensure that our parent company in the United States provide an adequate level of data protection by entering into appropriate data transfer agreements based on Standard Contractual Clauses and performing data protection assessments of data transfer arrangements as appropriate.
For how long do we retain the camera data?
We will retain the camera data only for as long as necessary to fulfill the purposes outlined in our Test Vehicles Privacy Notice, unless a longer retention period is required or permitted by law.
Your Statutory Rights
Under the conditions set out under applicable law, you may have the following rights:
- Right of access: The right to obtain from us confirmation as to whether your personal data is being processed, and, where that is the case, to request access to the personal data. The access information includes — inter alia — the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. You also have the right to obtain a copy of the personal data undergoing processing. Subject to applicable law, we may charge a reasonable fee for copies, based on administrative costs. The right of access is not an absolute right and the interests of other individuals may restrict your right of access.
- Right to rectification: The right to obtain from us the rectification of inaccurate personal data concerning you.
- Right to erasure (to be forgotten): The right to ask us to erase your personal data. However, such right to erasure may be limited. Since the identification of the data subject is not required for the processing of the data, this is not carried out. Pursuant to Article 11 of GDPR, personal data may nevertheless be deleted if further data is provided by the data subject to identify the person. To do so, please fill out the Right to Erasure Request Form.
- Right to restriction of processing: The right to request restriction of processing of your personal data, in which case, and if the requirements are met, it would be marked and processed by us only for certain purposes.
- Right to data portability: Under certain circumstances, the right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and the right to transmit the personal data to another entity without hindrance from us.
- Right to object: The right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us, where we rely on either our legitimate interests (or those of a third party) or where processing is necessary for the performance of a task carried out in the public interest, as the legal basis, and we can be required to no longer process your personal data. If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us. Exercising this right will not incur any cost. Such a right to object may not exist, in particular, if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
Please note that these rights and options described above are subject to limitations and exceptions under applicable law. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will try to resolve your concern.
To exercise any of the above rights or choices (or any other rights under applicable law), please contact us at email@example.com. Our Data Protection Officer is Thorsten Ihler (firstname.lastname@example.org). Kindly note that any requests sent through the aforementioned email will be distributed to members of the MicroVison’s privacy team based on their need to know, and subsequently forwarded to the DPO.