Data processing automated vehicles overview QR

Introduction

Autobrains Technologies Ltd. and any subsidiaries thereof (“us“, “we“, “Autobrains” or “the Company“) provides solutions for the next generation of vehicles and mobility (the “Services“). We provide our customers (each, a “Customer“) solutions that deliver safer, superior performance at reduced energy usage and lower costs. The robust signature-based representation and unsupervised learning capabilities enable a more detailed, comprehensive, and precise understanding and interpretation of the vehicle’s surroundings – in real-time.

To accomplish this goal, we use cutting-edge technology to collect data, including video recordings of the vehicle’s surrounding area, through our advanced driver-assistance system (“ADAS“) smart cameras.

These ADAS smart cameras are used to automatically detect and respond (e.g., avoid) to, for example, other cars and motorcycles, traffic signs, traffic lights, and vulnerable road users, which can also include individuals (“you“).

This privacy policy (“Privacy Policy“) will help you understand what types of information we collect through our services, how the Company uses it, and what choices you have. We encourage you to read this Privacy Policy carefully and use it to make informed decisions.

 

Collection and Storage of Your Personal Information

Personal Information is information that identifies an individual or that may, with reasonable effort, identify an individual.

As explained above, our vehicles are equipped with ADAS smart cameras, which record the vehicle’s surrounding area. In order to provide comprehensive and precise understanding and interpretation of the vehicle’s surroundings, we may inadvertently collect and use the following types of Personal Information about you:

  • Video recordings of individual road users (passing pedestrians and/or drivers)
  • Vehicle license plates
  • Geolocation data

To clarify, our ADAS smart cameras’ data is only used to detect and track “traffic objects” such as cars, motorcycles, pedestrians etc., and to further train our algorithms for this purpose, but it is not intended for the purpose of processing any personal information or to identify any particular individual.

 

Legal Basis for Processing

Our legal basis for collecting and using your Personal Information which may be included in our vehicles’ video recordings is the legitimate interest of Autobrains in developing and improving our Services which are designed to create solutions for better vehicular safety, as well as ADAS and autonomous driving solutions.

Additionally, we rely on the legitimate interest legal basis in processing such data for the purposes of protecting and securing our Services, for the exercise and defense of legal claims, and to comply with legal obligations.

 

Where we rely on our legitimate interests to process your Personal Information, you have the right to object.

If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us through the contact details available below.

 

How We Use Personal Information?

In addition to the purposes listed herein, the Personal Information we collect is used for the following purposes:

  • Development, Provision and Improvement of Service – we will use Personal Information for the development, provision and improvement of our Services such as for the purpose of training and improving our ADAS algorithms and smart camera solutions.
  • Compliance with legal and regulatory requirements – we may use your Personal Information to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.
  • Protecting our interestswe may use your Personal Information when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our Services and protect the rights and property of the Company, its Customers and/or partners.

 

With Whom Do We Share The Personal Information We Collect?

  • Affiliated companies: we may share Personal Information internally within our group of companies, for the purposes described in this Privacy Policy.
  • Service providers and partners: we work with service providers that work on our behalf and partners that complement our Services, which in each case may need access to certain Personal Information in order to provide their services to us (collectively, “Service Providers“). These companies include our partners and those we have hired to provide various services, such as cloud storage.
  • Mergers and acquisitions: we may share your Personal Information if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, business combination, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy.
  • Compliance with laws and law enforcement entities: we may disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), required to comply with our legal obligations, to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being illegal. We also may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements. We will only disclose the minimum amount of Personal Information that is required for compliance with such legal requirements.

Third parties who we may share your Personal Information with will be required to meet our standards on processing information and security. The Personal Information we provide them will only be provided in connection with the performance of their function.

 

Your Rights

Certain jurisdictions provide individuals with certain statutory rights to their Personal Information. You may have the right to certain actions to your Personal Information such as:

  • To receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with certain supplementary information.
  • To receive Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format.
  • To request rectification of your Personal Information that is in our control.
  • To request erasure of your Personal Information.
  • To object to the processing of Personal Information by us.
  • To request to restrict processing of your Personal Information by us.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

If you wish to raise a complaint on how we have handled your Personal Information, you can contact us at the contact details available below.

If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with applicable laws, you can file a complaint to the applicable data protection authority.

 

For How Long Do We Retain the Personal Information We Collect?

We retain the information we collect (including any Personal Information which may inadvertently be collected) for as long as needed to achieve the purpose for which it was collected, namely to develop and operate our Services, and where applicable, to comply with our legal obligations or the achieve any other purpose of collection described herein.

Retention periods will be determined taking into account the type of the Personal Information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused Personal Information at the earliest reasonable time.

 

International Transfer (for EEA and UK residents)

Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the EEA or UK.

In these instances, we will transfer your Personal Information only to such countries as approved by the European Commission or the UK Information Commissioner Office as providing adequate level of data protection, or enter into agreements ensuring an adequate level of data protection and which include legally approved data transfer mechanisms (such as the EU Standard Contractual Clauses and/or the UK Data Transfer Addendum).

 

How Do We Safeguard Your Personal Information?

We take great care in implementing and maintaining the security of your Personal Information. We employ industry standard procedures to ensure the confidentiality, integrity, and availability of your data, safety of your Personal Information, and prevent unauthorized use of any such information.

If you feel that your privacy was treated not in accordance with this Privacy Policy, please contact us directly through the contact details available below.

 

Changes to the Policy

We reserve the right to change this Privacy Policy at any time, so please revisit this page frequently.  All other changes to this Privacy Policy are effective as of the stated “Last Revised” date.

 

Contact Us

We are the controller of Personal Information under the General Data Protection Regulation (EU) Regulation 2016/679 (“GDPR“).

If you have any questions about this Privacy Policy or if you would like to exercise any of the rights mentioned herein with respect to your Personal Information, please contact us at:

Autobrains AI Technologies GmbH

Pasteurstraße 18, 10407 Berlin, Germany

Email: privacy@autobrains.ai

 

California, Virginia, Colorado and Utah Residents

This part of the Privacy Policy addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199) (“CCPA“); the California Privacy Rights Act (“CPRA“); Virginia Consumers Data Protection Act of 2021 (“VCDPA“); Colorado Privacy Act of 2021 (“CPA“); and Utah Consumer Privacy Act (“UCPA“), (collectively: “State Laws“).

What information we process

In the preceding 12 months, we have collected, and or disclosed the following categories of Personal Information (as this term is defined under State Laws):

Category of Personal Information Collected Personal Information Collected Categories of recipients to whom Personal Information was disclosed
Identifiers Vehicle license plates

 

Service Providers
Audio, electronic, visual, thermal, olfactory, or similar information Video recordings Service Providers
Geolocation data Physical location or movements Service Providers

In addition, in the past 12 months, we have collected the following categories of Sensitive Personal Information (as this term is defined under VCDPA and UCPA) from Virginia and Utah residents:

Category of Personal Information Collected Personal Information Collected Categories of recipients to whom Personal Information was disclosed
Precise geolocation data Physical location or movements Service Providers

Sources of Personal Information

In the 12 preceding months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:

  • Our ADAS smart camera.

Purposes for collection and disclosure of Personal Information

Our purposes for collecting Personal Information can be found above, under the section “How we use the information we collect”. Our purposes for disclosing Personal Information to third parties can be found above, under the section ” With Whom Do We Share the Personal Information We Collect?”.

Sale and Share of Personal Information

We do not “sell” or “share” (as these terms are defined under applicable State Laws) any Personal Information.

 

User rights under State Laws

State Laws provide consumers with specific rights regarding their Personal Information. This section describes the rights you may have under these laws and explains how to exercise those rights.

Access to Personal Information

You may request that we disclose to you the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which your Personal Information is collected, the business or commercial purpose for collecting your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any categories of Personal Information about you that we sold, the categories of third-parties with whom we have shared your Personal Information, and the business or commercial purpose for selling your Personal Information, if applicable.

You also have the right to obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format.

Deletion Requests

You may have the right to request that we delete any Personal Information collected from you and retained, unless an exception applies.

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Information, unless an exception applies.

Right to Correction

You have the right to request that we rectify inaccurate information about you.

Right to Opt-Out of Selling or Sharing of Personal Information

Certain State Laws grant consumers the right to opt out of “selling” or “sharing” their Personal Information (as these terms are defined under applicable State Laws), from using their Personal Information for targeted advertising and from using their Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

We do not sell, share, or use your Personal Information for any of the abovementioned purposes.

Right to data portability

You may have the right to obtain your Personal Information in a portable and readily usable format.

Right to non-discrimination

You have the right to be free from any discrimination for exercising your rights under State Laws. Should you exercise any of your rights under State Laws, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.  However, in some circumstances, for example where you have requested or consented to our services that use your Personal Information to provide the service, we may not be able to provide a service if you choose to delete your Personal Information.

Right to Limit Use of Sensitive Personal Information

We do not engage in uses or disclosures of Personal Information that would trigger the right to limit use of sensitive Personal Information under State Laws.

 

Exercising Your Rights

You can exercise your rights by submitting a verifiable consumer request to our physical address (as written below in the “Contact Us” section) or to our email address: privacy@autobrains.ai.

Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information.

The request must:

  • Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative thereof.
  • Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
  • We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

If you are a Virginia or Colorado resident, you have the right to appeal a rejection to your request. The appeal request shall be submitted through our Data Privacy Officer’s email address: privacy@autobrains.ai or by sending a mail to our physical address specified in the Contact Us section.

If your appeal is denied, you may lodge a complaint with the applicable Attorney General, as follows:

 

Designating Agents

If you are a California resident, you can designate an authorized agent to make a request under the CCPA or the CPRA on your behalf if:

  • The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
  • You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA or the CPRA.

Last revised: December 2022

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