PRIVACY POLICY for PERSONAL INFORMATION in ROAD FOOTAGE

Last revised: June 8th, 2026

Introduction

Autobrains Technologies Ltd. and its affiliates (together, “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. 

Autobrains’ Services include, without limitation, our advanced driver-assistance system and autonomous driving systems (collectively, “ADAS“). The operation of ADAS is based, amongst other things, on smart camaras installed on the ADAS-equipped vehicles, which enable such vehicles to automatically detect and appropriately respond (e.g., avoid) to relevant traffic objects in their roadway, for example, other cars and motorcycles, traffic signs, traffic lights, vulnerable road users, etc.  

As part of our R&D efforts, we install ADAS cameras on certain test vehicles for the purpose of collecting certain data, including video recordings of the test vehicle’s surrounding area and the relevant traffic objects in its roadway (“Road Footage”), and use such data in order to develop, improve and train ADAS, its algorithms and other Services. We may also receive similar video recordings from our business partners for these purposes, also deemed as “Road Footage” herein.

In certain instances, Road Footage may incidentally include and become associated with certain Personal Information (as defined below). 

To clarify, our R&D objectives only require us to detect, track and analyze “traffic objects” such as cars, motorcycles, pedestrians etc., and do not require the processing of any Personal Information pertaining to a particular individual and/or the identification of any particular individual. Any collection and processing of Personal Information is incidental, stemming from the nature of our activities and inherent technological limitations.

This Privacy Policy for Personal Information in Road Footage (“Privacy Policy“) will help you understand what types of Personal information we may collect as part of the Road Footage, how the Company uses it, and what choices you may have. We encourage you to read this Privacy Policy carefully and use it to make informed decisions.

This Privacy Policy does not apply to Company’s collection and processing of Personal Information pertaining to users of our website in. For your convenience, our Website Privacy Policy is available here https://autobrains.ai/privacy-policy 

This Privacy Policy does not apply to Company’s collection and processing of Personal Information about job candidates. For your convenience, our Candidate Privacy Policy is available here https://autobrains.ai/candidate-privacy-policy/ 

 

Collection and Storage of Your Personal Information

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

• Road Footage collected by the Company may include video recordings of individual road users (passing pedestrians and/or drivers) and vehicle license plates.

• Certain video recordings may also be associated with geolocation data on the area in which they were collected.

(all together, “Personal Information“).

For the avoidance of doubt, any Road Footage which does not include Personal Information, including Road Footage containing recording of individuals that cannot be reasonably identified, are outside the scope of this Privacy Policy and may be used, processed and shared by the Company for any purposes whatsoever at its sole discretion.  

Legal Basis for Processing 

Our legal basis for collecting and using your Personal Information which may be included in our Road Footage is the legitimate interest of Autobrains in developing, testing, validating and improving our Services which are designed to create solutions for better vehicular safety, including ADAS and autonomous driving solutions. 

Additionally, we rely on our legitimate interest in processing such data for the purposes of protecting our and our Customer’s interests, and we may also process such data as necessary in order to comply with a legal obligation, all as further described below. 

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?

The Road Footage we collect is used for the following purposes:

• Development, Testing, Validation and Improvement of Service – we will use Road Footage for the development, training, validation 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 Road Footage 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 Road Footage when we believe it’s necessary in order to take precautions against liabilities, secure of Services, exercise legal claims, investigate and defend ourselves against any third-party claims or allegations, and protect the rights and property of the Company, its Customers and/or partners. 

With Whom Do We Share The Personal Information We Collect?

The Road Footage we collect may be shared with the following third parties:

• Affiliated companies: we may share Road Footage 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 Road Footage 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 Road Footage 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..

Third-parties who we may share Road Footage with will be required to meet our standards on processing information and security. The Road Footage 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:

• Request access. This means that you may receive a copy of the Personal Information we hold about you.
• Request correction. This means that you may ask us to correct or complete inaccurate, incomplete, outdated, or unclear Personal Information that we hold about you.
• Request erasure. This means that you may ask us to delete or remove Personal Information that we hold about you, subject to applicable law.
• Object to processing. This means that you may object to the processing of your Personal Information in certain circumstances, subject to applicable law.
• Request restriction of processing. This means that you may ask us to suspend the processing of your Personal Information in certain circumstances, subject to applicable law.
• Data portability. This means that you may request that we transfer your Personal Information to you or to a third party, where applicable.
• Withdraw consent at any time. This means that you may withdraw your consent where we are processing your Personal Information based on your consent, subject to applicable law

Additionally, in accordance with the provisions of the Israeli Protection of Privacy Law, 5741-1981, you are entitled to review your Personal Information held by us and request its correction, subject to the conditions specified therein.

However, please note that these rights are not absolute, and may be limited or restricted under applicable laws. 

If you wish to raise a complaint about 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 Road Footage 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.

International Transfer 

Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the EEA, UK, or other jurisdictions which limit or regulate such transfer of Personal Information. 

In these instances, we will transfer your Personal Information only to such countries as approved by the applicable supervisory authority (such as 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).

Where applicable, 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 employ procedures to ensure the confidentiality, integrity, and availability of your Personal Information, 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 re-visit this page frequently.  All 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“) and the United Kingdom General Data Protection Regulation (“UK GDPR”), to the extent applicable. 

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

Moosacher Straße 82a | 80809 München

Email: privacy@autobrains.ai

Autobrains Technologies Ltd.

52 Menachem Begin St., 6713701 Tel-Aviv, IsraelThe e-mail address of our Data Protection Officer is: privacy@autobrains.ai

 

US Residents

This part of the Privacy Policy addresses the specific disclosure requirements under the applicable laws pertaining to data privacy, data security and the protection of personal information in the United States, including in California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Florida, and Montana (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	Affiliates and Service Providers
Electronic, visual, or similar information	Video recordings	Affiliates and Service Providers
Geolocation data	Physical location or movements	Affiliates and Service Providers

 

In addition, in the past 12 months, we have collected the following categories of Sensitive Personal Information (as this term may be defined under certain States Laws), as part of the applicable Road Footage:

Category of Personal Information Collected	Personal Information Collected	Categories of recipients to whom Personal Information was disclosed
Precise geolocation data	Physical location or movements	Affiliates  and 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.
• Business partners.

Purposes for collection and disclosure of Personal Information

Our purposes for collecting Personal Information can be found above, under the section “How We Use Personal Information”. 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 or their equivalents 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. Please note that the scope of these rights may vary by state.

Access to Personal Information 

You may have a right to 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, the identity or 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 may 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.

Right to Correction

You may 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, 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 may have the right to be free from any discrimination for exercising your rights under State Laws.  

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 or our Data Protection Officer’s e-mail address (as written above in the “Contact Us” section): 

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 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 resident of certain states, including Virginia, Colorado, Texas or Oregon, you have the right to appeal a rejection to your request. The appeal request shall be submitted to our physical address our Data Protection Officer’s e-mail address (as written above 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 Texas resident, you can lodge a complaint with the Texas Attorney General at https://consumerprotection.texasattorneygeneral.gov/consumercomplaintportal/s/flow/TCP_Complaint_Input_Data_Privacy. 

• If you are an Oregon resident, you can lodge a complaint with the Oregon Department of Justice at https://justice.oregon.gov/consumercomplaints/OnlineComplaints/OnlineComplaintForm/en. 

Designating Agents

Where required or permitted under applicable State Laws, you may designate an authorized agent to submit privacy requests on your behalf, including requests to access, delete, correct, or opt out of the sale, sharing, or targeted advertising of your Personal Information.

We may require an authorized agent to provide proof that you have authorized them to act on your behalf. Depending on the nature of the request and applicable law, we may also require you to verify your identity directly with us and confirm that the authorized agent has permission to submit the request.

We may deny a request submitted by an authorized agent if we cannot reasonably verify: the agent’s authority to act on your behalf; or your identity.

Authorized agents may be required to follow specific verification procedures depending on the type of request and applicable legal requirements.

If you have provided an authorized agent with a valid power of attorney under applicable State Law, we will process requests submitted in accordance with such authority, subject to verification requirements as permitted by law.