Data protection notice in relation to development vehicles for autonomous driving - Rimac Technology

Scope

At Rimac Technology we are working hard to improve road safety and automated driving systems. For this we also need to collect and process data outside the vehicle. Some of this data might be personal data. With this data protection notice (Notice) we want to inform you how our development vehicles collect and process personal data from the vehicle environment.

Data Controller

We value and protect privacy and personal data and treat this data confidentiality. In processing personal data, we comply with the EU General Data Protection Regulation (2016/679; GDPR), in particular.

Data controller responsible for collection and processing of data is Rimac Technology d.o.o., established in Republic of Croatia, 10431 Sveta Nedelja, Ljubljanska 7, OIB 70036017051.

For any questions about this Notice please contact data protection officer at: dpo@rimac-technology.

Data we collect and process

First of all, our development vehicles are marked to notify about the recording of the environment. Development vehicles are equipped with a sensor set composed of cameras, and/or radars, and/or lidar and/or ultrasonic sensors. They record the time of the measurement and the information from the surrounding of the vehicle (e.g., houses, trees, other vehicles, pedestrians) and store them for analysis for the purposes described below. We don’t collect audio recordings of the environment, only video recordings.  Also, we collect the information from the environment by using 3D Point clouds technology. This enables us to classify the categories of objects present in the point cloud (e.g., car, truck, motorbike, person) but without possibility to identify an individual.  Similarly, we use the reflection data from the vehicle radars for detecting vehicles, their position in 2D and their relative speed. This enables us to get to know the category of detection (person, vehicle) without being able to identify them. Last, but not least, we use the reflection data from ultrasonic sensors, which enable us to detect only the distance of an object without its identification.

Purposes for which we process data

We use the data about the environment of vehicle exclusively for researching and developing fully automated driving and for improving road safety.  We need to process the data to identify what is happening around the vehicle and predicting what may happen in short-term future (prediction), to know where the vehicle is and what is vehicle’s orientation (the localization) and to dynamically compute safe trajectory for the vehicle (the motion planner).

We are not interested in identifying individuals, nor in details about objects, nor to whom they belong (e.g., license plates of vehicles). All traffic objects are only categorized as “cars”, “bicycle”, “truck”, “person”, etc. and some of them have additional attributes such as their orientation and posture for pedestrians (e.g., standing, sitting, laying).

By using sensor data, we also aim to categorize the weather condition (e.g., sunny, rainy, foggy, snowy), the type of road (e.g., city, country, track), the type of road surface (dry, wet, snow, icy) and the quality of the road surface (e.g., pothole).

Legal basis for processing

The legal basis for collecting and processing data of the vehicle environment which might qualify as personal data is a legitimate interest according to Art.6.f) of the GDPR. Legitimate interest for processing of the vehicle environment data results from interest in developing the autonomous driving and improving the road safety. We believe that this interest is common for us and the public.  Also, we would not be able to adequately develop autonomous driving functionality and thus improve the road safety without collecting and processing the data from vehicle environment. While it is necessary to process this data, at the same time most of this data is not personal data, but nevertheless all data is protected.

Data storage

We store your personal data only as long as required for the intended purpose.

Sharing of data

The data is stored locally on our servers and only authorized personnel of Rimac Technology have access to these data on need-to-know basis. We might share data only with our subcontractors if we need their help in developing autonomous driving. In that case they act as our data processors within the meaning of GDPR which process and protect the data on our behalf based on strict contractual obligations. Also, we may share data with public authorities if we would be required under mandatory law.

Protection of data

We apply appropriate technical and organisational measures to ensure a security of data, including inter alia ability to ensure the ongoing confidentiality, integrity, availability and resilience.

Transfer of data outside EU

In principle we do not transfer personal data outside European Union. If there will be need for such international transfer (e.g., our sub-contractor is from non-EU country), we would use the EU Standard Contractual Clauses with appropriate technical and organisational measures and additional safeguards in place, to ensure that personal data is processed as required by the EU data protection standards.

Data subjects’ rights

If you think that your personal data is processed by our development vehicles, you may claim certain rights under the GDPR. If the respective GDPR requirements are fulfilled, including to proving your entitlement to claim these rights, we will provide you with the right to access, rectification, erasures of personal data, restriction of processing, and right to object to personal dana processing. Also, you have a right to lodge a complaint to the national supervisory authority for protection of personal data. Please contact dpo@rimac-technology.com

Changes to this Notice

From time to time, we might update this Notice. The updated Notice will be published on our website.