Last update: October 2022
MOTOR Ai takes the protection of your data very seriously. We are committed to protecting your privacy. Please read this privacy notice carefully as it contains important information about how we collect, store, process, transfer, share and use your personal information. The data is collected and processed as part of the operation of our autonomous test vehicles.
This Privacy Notice applies to information we collect through our in-vehicle sensors, cameras and microphones in connection with MOTOR Ai’s autonomous driving feature (“Autonomous Driver”). MOTOR Ai's test vehicles are marked as such and collect data on public and private land. In doing so, data can potentially be collected and processed by anyone who is in the vicinity of the test fleet. We hereby inform all natural persons how and why MOTOR Ai processes personal data.
1. WHO IS RESPONSIBLE FOR THE PROCESSING OF THE DATA?
MOTOR Ai GmbH, Pfuelstraße 5, 10997 Berlin, Germany, email: privacy@motor-ai.com ("MOTOR Ai", "We", "Us" or "Our") is responsible for the collection, processing and Use of personal data in connection with our Autonomous Driver, the autonomous driving software developed by MOTOR Ai and used in our vehicles.
2. WHAT DATA DO WE PROCESS, FOR WHAT PURPOSE AND ON WHAT LEGAL BASIS?
2.1 MOTOR Ai is a technology company developing autonomous driving system and related services. We use test vehicles for research and development, testing and verification of our products. Our goal is to improve MOTOR Ai autonomous driving algorithms to further develop MOTOR Ai autonomous driver. To achieve this goal, we need to test our autonomous driving algorithms in real scenarios and with real data.
2.2 We have therefore equipped vehicles with additional sensors (e.g. lidar, radar, ultrasound, GPS), cameras and microphones in order to collect raw data and video material ("raw data") while driving on public roads. Recordings of pedestrians, cars, motorcycles, bicycles, different types of roads, road markings, traffic signs, parking lots and other objects as well as their position and movement in the vicinity of our test vehicles are processed in order to document vehicle behavior in traffic. The same applies to the recording by the microphones, since the acoustic perception of the surroundings is also essential for the overall view of road traffic (e.g. when sirens are used by rescue vehicles). The vehicles will travel across 27 European countries to collect various road information.
2.3 During collection, our sensors and cameras may collect some personally identifiable information, such as pedestrian faces or vehicle license plates.
2.4 The raw data we collect is first stored encrypted on board. In a further step, the personal data collected during collection is made unrecognizable using anonymization algorithms. We apply face blurring to artwork. In a final step, all raw data is deleted after the anonymization process is complete. This ensures that no personal data is used to train the algorithms.
2.5 The legal basis for the collection, processing and storage of the above personal data is Article 6 (1) f) GDPR. Our legitimate interest lies in improving our autonomous vehicles, systems and technologies. The data is collected for research, development and testing purposes. The approval supports the further development of algorithms for various autonomous driving functions and to ensure the safety of road users, vehicles and other objects.
2.6. In the event that our vehicles are involved in an incident or accident, we will use the data we have collected to clarify liability issues or legal responsibilities, for the purpose of accident research and, if necessary, to improve our product. This is processed, anonymized and blurred data that we store in the black box.
3. DISCLOSURE OF YOUR PERSONAL INFORMATION
3.1 MOTOR Ai GmbH. In order to ensure proper training of our autonomous driving algorithms, we share the data after anonymization, in particular with our development department.
3.2 Service Providers and Advisors. Personal information may be shared with third party service providers who perform services on our behalf, which may include collecting raw data and ensuring anonymization using state of the art technology.
3.3 Law enforcement agencies, regulators and other parties for legal reasons. Personal information may be disclosed to third parties if required to do so by law or if we reasonably believe that such action is necessary to (a) comply with the law and reasonable law enforcement requests; (b) protect the security or integrity of the Service; and/or (c) exercise or protect the rights, property, or personal safety of users of the Service or others.
4. RETENTION PERIODS
4.1 We only keep your personal data if this is necessary to fulfill the purposes for which we collected it. After completing the collection of the raw data, we ensure immediate anonymization. The raw data is deleted immediately after anonymization.
4.2 After anonymization, we will use the data for research, development and testing purposes.
4.3. Legal regulations or obligations may require longer storage of the data (e.g. permits for testing or other requirements). After these periods have expired, your personal data will be deleted or stored anonymously.
5. STORAGE AND TRANSMISSION OF YOUR PERSONAL DATA
5.1 Security. We take appropriate technical and organizational measures to protect your personal data from unlawful access or unauthorized disclosure.
5.2 Storage of Data. Your personal data will be stored within the European Union. The anonymization takes place in Berlin, Germany.
5.3 International transfers of your personal information. To ensure that personally identifiable information has been removed, all raw data is anonymized before any Autonomous Driver-related data transfer takes place. After the anonymization has been completed, we can transmit the data to MOTOR Ai GmbH. Any international transfer of your personal data will be either: (a) to a country or territory which ensures an adequate level of protection of the rights and freedoms of data subjects with regard to the processing of personal data, as determined by the European Commission; (b) to a third party that is a member of a compliance regime recognized as providing an adequate level of protection for the rights and freedoms of data subjects, as determined by the European Commission; or (c) under appropriate safeguards such as standard contractual clauses published by the European Commission.
6. YOUR RIGHTS REGARDING YOUR PERSONAL DATA
6.1 This section applies to you if you are located in the EEA.
6.2 In accordance with applicable data protection law, in connection with the processing of your data, you have the following rights in relation to your personal data that we store:
6.2.1 Right to information and a copy of the data. You have the right to:
6.2.1.1 a confirmation as to whether and where we are processing your personal data;
6.2.1.2 Information about the categories of personal data that we process, the purposes for which we process your personal data and information about how we determine the applicable retention periods;
6.2.1.3 information about the categories of recipients with whom we may disclose your personal information; and
6.2.1.4 a copy of the personal data we hold about you.
6.2.2 Right to Erasure. You have the right, under certain circumstances, to request the immediate erasure of your personal data where further processing of that data is not justified. Excluded is the processing of data to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to establish, exercise or defend legal claims.
6.2.3 Right to Rectification. You have the right to have inaccurate or incomplete personal information we hold about you rectified without undue delay.
6.2.4 Right to restriction of processing. You have the right, in certain circumstances, to request that we restrict the purposes for which we process your personal data where further processing of the personal data is not justified in that way (e.g. where the accuracy of the personal data is contested by you). This is for a period enabling us to verify the accuracy of that personal information.
6.2.5 Right to data portability. You have the right, in certain circumstances, to obtain a copy of the personal data that you have provided to us in a structured, commonly used and machine-readable format that supports reuse, or to request that your personal data be transmitted to another person.
6.2.6 RIGHT TO OBJECT. YOU HAVE THE RIGHT TO OBJECT THE PROCESSING OF YOUR PERSONAL DATA ON THE BASIS OF LEGITIMATE INTERESTS.
6.3 If you wish to exercise these rights, please contact us using the contact details at the end of this privacy notice.
6.4 You also have the right to lodge a complaint with the relevant data protection authority if you believe that our processing practices are not in line with data protection laws. You can find the data protection authority responsible for you on the website of the European Data Protection Board by following this link: https://edpb.europa.eu/about-edpb/about-edpb/members_en
We assume that the Berlin Commissioner for Data Protection and Freedom of Information (BInBDI) is responsible as the lead supervisory authority. The contact details can be found under the following link: https://www.datenschutz-berlin.de/ueber-uns/kontakt
7. CHANGES TO THIS PRIVACY NOTICE
7.1 We review our privacy notices, policies and procedures from time to time to make improvements and refinements. Accordingly, we may update this privacy notice from time to time, so you should check this page regularly.
7.2 If we make material changes to this Privacy Notice, we will update the "last updated" information at the top of this Privacy Notice. Changes to this privacy notice will be effective when posted on this page.
8. PRIVACY CONTACT
8.1 If you have any questions about this data protection notice, the processing of your personal data in connection with the Autonomous Driver or if you want to reach our data protection officer, you are welcome to contact us at privacy@motor-ai.com or by mail to MOTOR Ai GmbH , Pfuelstrasse 5, 10997 Berlin.
