Privacy Notice

Collection of video, image and audio data as part of the project “Automated Driving Alliance” between Robert Bosch GmbH and CARIAD SE

 

The protection of personal data is a top priority for Robert Bosch GmbH and CARIAD SE (hereinafter "Cooperation Partners") or (“We”) and is a major factor in all our business processes.

The Cooperation Partners conduct street recording activities to collect data necessary for the research, development, and testing of driver assistance systems, automated driving, driving functions, and other services (“Street Recording”) in a partnership under a joint responsibility. This privacy notice describes how We and our suppliers collect, process, use and share personal data (also referred to as “personal information” in some jurisdictions) collected during the Street Recording.

1. What personal data do we collect?

We or our suppliers conduct the Street Recording in public traffic areas and (insofar as legally permissible) on private factory, testing, and other facilities.

The vehicles used for Street Recording are equipped with camera systems with different angles of coverage, focal lengths and sensor technologies, and in some cases with external microphones and other sensor systems. These systems collect, process and store video, image and audio data from the vehicle environment for the purposes described in Section 3 of this privacy notice.

This data may - depending on the individual use-case - also include the following personal data:

We may be able to link this data to other data collected from other sensor systems on the vehicle used for Street Recording (such as radar and LIDAR, which sense the distance between the vehicle and a person or object) as well as location or GPS position and date and time stamp.

While faces may appear in the collected video and image data, our further processing focuses on their characteristics as 'objects' within the environment (e.g., shape, movement patterns) for technical system development, not for identifying, locating or profiling individual persons. We also do not use this data for biometric identification or authentication purposes.

 

2. Who is responsible entity for the processing of my personal data, and who can I contact for further information?

Within the scope of the “Automated Driving Alliance” project, the Cooperation Partners are jointly responsible for the data processing activities described below.

For these specific data processing activities, the legally required joint controllership agreement has been concluded between the Cooperation Partners.

For more information on the joint controllership, please see Section 8.

Joint Controllers:

Robert Bosch GmbH
Robert-Bosch-Platz 1
70839 Gerlingen- Schillerhöhe
Germany

and

CARIAD SE
Major-Hirst-Straße 7
38442 Wolfsburg
Germany

If you would like to contact us, please use the following contact options:

E-Mail: privacy@automated-driving-alliance.com

To exercise your data subject rights, request the removal of your image, ask a privacy-related question or report data protection incidents, you can contact both Cooperation Partners Data Protection Departments:

Data Protection Officer - Robert Bosch GmbH:

Abteilung Informationssicherheit und Datenschutz Bosch-Gruppe (C/ISP)
Postfach 300220
70442 Stuttgart
Germany

E-Mail: DPO@bosch.com

Data Protection Officer - CARIAD SE:

Major-Hirst-Straße 7
38442 Wolfsburg
Germany

E-Mail: privacy@cariad.technology

3. Why do We collect and use personal data and on which legal bases?

The purposes of the personal data processing are research, development and testing in the areas of driving assistance systems, automated driving, driving functions and other services, including the documentation of these processes and including the documentation of these processes and adherence to statutory and regulatory requirements."

Research, development and testing of such systems require their use in test vehicles under real environmental and traffic conditions - also in public traffic areas - including the acquisition, processing and storage of video, image and audio recordings during and after these operations.

These data sets are used to research, develop and test technical systems for the perception and classification of road users, vehicles, infrastructure and other objects in the context of traffic and environmental situations.

Persons, vehicles, other objects and audio information will be analyzed, classified and processed as "objects" in the context of traffic and environmental situations, e.g. as

The primary legal ground of the processing is the pursuit of our legitimate interests in conducting research, development, and testing procedures for driving assistance systems, automated driving, driving functions, and other services which are crucial for enhancing road safety and transportation efficiency. Where required by applicable local law, we will also rely on other legal bases such as consent, contractual necessity, or compliance with a legal obligation.

4. Will the personal data be transferred to third parties?

The personal data is only shared with other companies affiliated with the BOSCH or CARIAD group, between Cooperation Partners, and with development partners, data processors or other third parties within purposes described above.

Personal data will only be shared with third parties where legally permissible.

Other service providers (in particular IT service providers as well as service providers for data processing / data evaluation), who may receive and process any of the personal data collected in connection with the Street Recordings in order to provide these services.

If personal data is transferred to recipients countries outside the region where you are located, and which may not guarantee a comparable level of data protection, we ensure that appropriate safeguards are in place. This may be through standard contractual clauses, binding corporate rules, or other recognized mechanisms.

If you are located in Canada, please note that your personal data may be processed in a foreign country (and, if you are located in Quebec, could be communicated outside Quebec), and may be accessible to courts, law enforcement and national security authorities of foreign jurisdictions. You may contact DPO@bosch.com to (i) obtain access to written information about Robert Bosch GmbH’s policies and practices with respect to service providers outside Canada, or (ii) to ask a question about the collection, use, disclosure or storage of personal data by service providers outside Canada for or on behalf of Robert Bosch GmbH.

5. Do We use your personal data for automated decision-making or profiling?  

No.

6. How long will We store the personal data?

The video, image data are processed and stored for as long as is necessary for the research, development and testing processes mentioned. If, on a case-by-case basis, there is a further legal basis or a further legitimate interest for continued storage and processing (for example, for the proper documentation of the aforementioned processes, due to legal retention obligations or other legal requirements), the personal data will be stored for a corresponding longer period of time.

7. What rights do you have?

You have the following rights, that can be exercised against any of the joint controllers.

 

8. Information on joint controllership

What is the reason for the joint controllership of the Cooperation Partners?

Robert Bosch GmbH and CARIAD SE work closely together in function and vehicle development as part of the “Automated Driving Alliance” project. This also applies to the processing of personal data, insofar as this has been collected by corresponding development vehicles. The Cooperation Partners have jointly defined the processing phases of this data in the individual process stages. They are therefore jointly responsible for the protection of your personal data within the process steps described below.

For which process stages is there joint controllership?

The joint controllership of the Cooperation Partners includes the collection, storage and further processing of video, image and audio data. The Cooperation Partners collect personal data on the vehicles’ systems and transmit it to a common IT system where the data is stored and can be accessed or processed by both Cooperation Partners for research, (further) development and testing purposes.

Outside the project, the Cooperation Partners can process the personal data under separate responsibility, provided this is legally permissible.

What have the parties agreed?

As part of their joint controllership, the Cooperation Partners have also agreed that the collection of personal data also fulfils the information obligations with regard to joint controllership.

What does this mean for data subjects?

Data protection rights can be asserted both with Robert Bosch GmbH and with CARIAD SE through the contact data provided in Section 2. The Cooperation Partners will inform each other without delay about requests from data subjects. They will provide each other with all information necessary to respond to such requests in a timely manner.

9. Amendments of our privacy notice 

We reserve the right to amend our privacy notice from time to time to reflect changes in the way We process your personal data. Please ensure that you are viewing the most recently revised version of our privacy notice.