Data Protection
Date
We, STRADVISION, Inc. ("STRADVISION" or "we", “our”), are committed to protecting all Personal Data that we collect and/or otherwise process as part of our business activities.
This Privacy Policy applies to our processing of your Personal Data that we collect by creating videos of public traffic and collecting related sensor data for the purpose of obtaining traffic data for the training, development and operation of our advanced driving assistance systems. “Personal Data” means all information that can be related to an identified or identifiable person, e.g., license plates and video images which show physical characteristics of individuals.
In this Privacy Policy, we inform you, inter alia, about the nature, scope and purpose of our processing of your Personal Data as well as your rights with regard to such processing.
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We, STRADVISION, Inc., headquartered at 5-308 Venture Bldg., Pohang Techno Park 394 Jigok-ro, Nam-gu, Pohang-si, Gyeoungbuk, 37668, South Korea, are responsible for the processing of your Personal Data under applicable data protection law, in particular, the General Data Protection Regulation (EU) 2016/679 (the "GDPR").
If you have any questions about this Privacy Policy or in general about data protection related to our business activities and products, you can contact us at https://www.stradvision.com/sv/en/contact, by using our online contact form or contact:
STRADVISION, Inc., 5-308 Venture Bldg., Pohang Techno Park 394 Jigok-ro, Nam-gu, Pohang-si, Gyeoungbuk, 37668, South Korea
You may also contact our data protection officer:
Kim Junhwan / junhwan.kim@stradvision.com
When you contact us, the Personal Data you provide to us (your e-mail address, name and telephone number, if applicable) will be stored by us in order to answer your questions. We delete the data collected in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
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We use recording vehicles which are distinctively marked with a camera symbol and equipped with special recording and sensor technology to make video recordings of public traffic and collect related sensor data such as GPS information. The video recordings and other collected information (together the “Recordings”) may include the following Personal Data:
· Faces, other characteristics, behaviour and surroundings of traffic participants and individuals in the vicinity of our recording vehicles;
· License plates, other characteristics and surroundings of vehicles in the vicinity of our recording vehicles;
· Timestamps of the collection of the above Personal Data.
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In a first step after creating the Recordings, faces, licence plates and similar information which clearly identify an individual person are blurred (i.e., made unrecognisable) by our anonymisation software. Such blurring of this type of Personal Data cannot be reversed and serves to implement the GDPR principles of data minimisation and privacy by design. The blurring therefore leads to anonymisation in accordance with the GDPR. Due to our special anonymisation technology, the Recordings edited in this way can still be used for the purposes outlined below. We do not retain any unblurred Recordings or share them with any third parties .
Subsequently, we use the Recordings including the data which has not been blurred (such as cars, streets and the environment of the streets including houses) to develop and train our advanced driving assistance systems. In particular, we use them to improve the accuracy of these systems at identifying traffic participants such as other vehicles and pedestrians as well as road signs and traffic surroundings.
Training and developing advanced driving assistance systems requires recordings of public traffic and its surroundings to simulate real traffic and environment conditions. Moreover, sensor information such as GPS location data or lidar data is used during operation of these systems to improve the detection of certain traffic objects such as road signs or traffic surroundings.
We aim to minimize the amount and intensity of the Personal Data remaining in the Recordings after the blurring, but we cannot exclude that the Recordings still contain information which allow an identification, for example because certain non-blurred data can by exception be considered personal data due to its unique characteristics (e.g. a unique car), or because of a failure of the blurring process (which under normal circumstances should not occur, but software failures can never be totally excluded). The Recordings therefore may still include certain of the Personal Data outlined in Section 2.
We do not process any Personal Data to identify you or other individuals that the data might relate to, and we minimize the collection and processing of such Personal Data as much as possible (see Section 8 for details). We are also not processing your Personal Data for the purpose of automated decision making or profiling.
Legal Basis:The above-described processing of your Personal Data is based on our legitimate interests to develop, train and operate our advanced driving assistance systems (Art. 6 para. 1 lit. f GDPR). We protect your interest as a data subject by not processing your Personal Data for identification purposes and by implementing technical and organisational measures that ensure that all relevant processing operations are compliant with applicable data protection law.
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We share the Recordings including your Personal Data for the purposes detailed in Section 3 of this Privacy Policy as described below:
· Our customers and prospective customers: We share the Recordings with our customers, if the Recordings are necessary for the operation of the advanced driving assistance systems purchased by them. Sometimes, we also demonstrate how our technology works for prospective customers by displaying short clips of the Recordings to showcase how our systems analyse the data in the Recordings. The legal basis for sharing such data is the same as for us (legitimate interests to develop, train and operate our advanced driving assistance systems in accordance with Art. 6 para. 1 lit. f GDPR).
· Service providers. We may share the Recordings with companies that provide services which we require for developing, training and operating our advanced driver assistance systems. These service providers process your Personal Data on our behalf and are limited by contractual provisions in their ability to use your Personal Data for purposes other than providing the relevant services to us.
· Local drivers: We engage local drivers who create the video recordings and collect the sensor information on our behalf and under our instructions.
· Courts, authorities or other parties: We may disclose (parts of) the Recordings to courts, authorities or other parties to comply with a court order, a legal requirement or legal procedure, including responding to relevant government or regulatory requests (such disclosures would be based on Art. 6 para. 1 lit. c GDPR).
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Yes, we transfer the Recordings to our headquarters in Korea to analyse them for developing, training and operating our advanced driver assistance systems. Privacy law in Korea ensures a level of data protection which is equivalent to the GDPR and its adequacy has been recognized by the European Commission in an adequacy decision pursuant to Art. 45 GDPR.
We do not transfer your Personal Data to any other third countries outside the EU.
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We only retain your Personal Data for as long as it is necessary for the purposes outlined in Section 3. In some cases, legal provisions under applicable law (e.g., product liability law) may lead to longer retention periods where we are either obligated or if it is our legitimate interest (e.g., if we need to hold on to the Recordings to defend ourselves against potential product liability claims) to retain the Personal Data for a longer period.
Unblurred Recordings are immediately deleted after our anonymisation software has blurred faces and license plates.
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a. General information: Under the GDPR and other applicable data protection law you have various rights with respect to our collection and use of your Personal Data. You can find out about your rights below.
You can exercise your rights by sending us an e-mail or contacting us via the contact details specified in Section 1.
We note that due to the nature of our processing which does not require the identification of individuals we are not obligated to maintain identification information (see Art. 11 GDPR) and, thus, we are unable to identify your Personal Data without additional information provided by you.
This is why you can only assert your rights if your request includes information about the location and time of the Recordings which may contain your Personal Data. Otherwise, it will be impossible for us to fulfil your rights.
We also note that the right to data portability and right to rectification which are described below are not applicable due to the nature of the Personal Data that we process.
b. Right of deletion: You have the right to ask us to delete your Personal Data. However, this right is subject to certain limitations where we may retain and use your Personal Data to the extent necessary to comply with our legal obligations.
If we retain your data in one of the aforementioned cases, its processing is restricted, i.e., your data is not processed for other purposes.
c. Right to object: You have the right to object to one or all processing operations with respect to your Personal Data. If you assert this right, we will re-assess our legitimate business interests and your data protection interests. We will only continue processing if (i) there are compelling legitimate interests for processing which override your interests, rights and freedoms, or (ii) processing is necessary for the establishment, enforcement or defence of legal claims.
d. Other rights: Right of access (Art. 15 GDPR), right to rectification (Art. 16 GDPR), right to restriction of processing (Art. 18), right to data portability (Art. 20 GDPR)
e. Right to make a complaint to a supervisory authority: You have the right to make a complaint at any time to a supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us via the contact details specified in Section 1.
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We take the protection of your Personal Data very seriously and maintain technical and organisational measures to ensure an adequate level of protection.
Internally, we apply a Personal Data protection policy based on ISO 27001:2013 (ISMS, "Information Security Management System") which entails that the efficacy of our data protection activities is monitored by our data protection officer.
We also implement various measures to comply with the GDPR principles of data minimisation and privacy by design. This includes:
· Blurring faces and license plates with our state-of-the-art anonymisation software;
· Narrowing the camera angle of our recording vehicles as far as possible for the purposes we are pursuing; and
· Ensuring that no recordings are made outside of traffic, for example when the recording vehicle is only parked.
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Our recording technology does not have the capabilities to distinguish between persons which are under or above the age of 16. Therefore, it cannot be avoided that Personal Data of children (faces) will be collected as Well. However, the faces will be blurred before any further processing takes place.
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This Privacy Policy may be updated from time to time to reflect changes in our business activities with respect to the Recordings or changes in the applicable law.
