Data processing automated vehicles overview QR2
Last revised: September 2023
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“).
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 test 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 pedestrians and other drivers such as you:
- Video recordings of individual road users (passing pedestrians and/or drivers)
- Vehicle license plates
- Geolocation data
- Additional data which may be captured through the ADAS smart cameras as visually visible 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 pertaining to a particular individual and/or to identify any particular individual (all together as “Personal Information“).
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.
In certain jurisdictions, such as Israel, we rely on your consent for the processing of personal information. If you do not wish to be captured by our ADAS cameras you may move out of the vicinity of our easily identifiable vehicles or contact us using the details provided below, at any time.
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 interests – we 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?
- 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.
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).
International Transfer (for Israeli residents)
Since we operate globally, it may be necessary to transfer data, including Personal Information, to third-parties (including our Services Providers) that may be located outside of Israel, including in countries that may provide a different level of data protection than as provided under Israeli law.
In these instances, we will transfer your Personal Information only after ensuring adequate data protection measures, such as entering into a data processing agreement that requires such foreign recipients to appropriately secure the Personal Information, and all in accordance with and subject to applicable law.
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.
Changes to the Policy
We are the controller of Personal Information under the General Data Protection Regulation (EU) Regulation 2016/679 (“GDPR“).
Autobrains AI Technologies GmbH
Pasteurstraße 18, 10407 Berlin, Germany
Autobrains Technologies Ltd.
52 Menachem Begin St., 6713701 Tel-Aviv, Israel
California, Virginia, Colorado and Utah Residents
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
|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.
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.
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: email@example.com.
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: firstname.lastname@example.org 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:
- If you are a Virginia resident, you can lodge a complaint with the Virginia Attorney General through his/her contact information available here: https://www.oag.state.va.us/contact-us/contact-info or file the complaint at: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.
- If you are a Colorado resident, you can lodge a complaint with the Colorado Attorney at https://complaints.coag.gov/s/contact-us.
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.