Data protection information on the collection of traffic and environmental data in video data recordings during test drives

In the following we explain how ALPS ALPINE EUROPE GmbH handles video recordings made during test drives on public roads.

A. Responsible Person
The person responsible for the processing is
ALPS ALPINE EUROPE GmbH ("ALPS ALPINE EUROPE"), (HRB 255899)
Ohmstraße 4
85716 Unterschleissheim.
B. Purposes of processing
The following describes how ALPS ALPINE EUROPE makes the video recordings and why.
ALPS ALPINE EUROPE uses traffic and environmental data for (further) development, testing and related documentation in, among other things, the development of driver assistance and driver information systems, consumer electronics and other developments.
For our development work, it is essential that we use the real-time road data to assess
- the functionality (quality) of the developed devices/software and
- the progress of the development and the improvement of the products.

Traffic and environmental data are all data recorded during a test drive in the public area around the test vehicle.
This data is recorded during test drives of specially marked vehicles, by sensors and cameras attached to them, and subsequently analysed by us.
Test vehicles can be any means of transport that we use for our development and testing.
C. Legal basis
Without invention, no progress.
As a global player in electronics and software development, ALPS ALPINE EUROPE is constantly striving to make your life easier and safer through innovation.
Therefore, ALPS ALPINE EUROPE has a legitimate ethical and business interest in collecting the traffic and environment data and storing it for the processing purposes in accordance with data protection law (Art. 6 I f) GDPR).
The use of the traffic and environment data is necessary, as without the recorded data, no evaluation of progress is possible in order to assess whether and to what extent the functionality of the products has improved.
Many of our developments are aimed at improving not just your comfort, but road safety in general.
Especially in the development of products that serve traffic safety, a recording of traffic and environmental data is necessary in order to adapt our products to the actual conditions and dangers in public road traffic.
Of course, ALPS ALPINE EUROPE endeavours to protect your rights by limiting and securing the use as much as possible.
Traffic and environmental data is not made public, but kept for internal use only and destroyed after each project.
Test drivers are instructed to avoid locations where particularly sensitive personal data could be recorded and to delete it if they become aware of it.
ALPS ALPINE EUROPE uses the traffic and environmental data for processing purposes only and no action is taken to identify recorded individuals.
The recorded environmental data is stored in an access restricted database and is destroyed after the expiry of the deletion periods.
D. Data categories and groups of persons concerned
The cameras make recordings of road users, such as pedestrians, cyclists, drivers, and other people, who are in the vicinity of the test vehicle, as well as of vehicles and licence plates of vehicles.
E. Recipients
ALPS ALPINE EUROPE internally restricts access to responsible personnel who are working on the projects in question and who need access in order to achieve the purposes for which the information is being used.
Should a transfer to third parties take place, or should those have access, we conclude appropriate data protection agreements with the cooperation partners or service providers (joint controllership as defined in Art. 26 I GDPR or data processing as defined in Art. 28 GDPR).
Depending on the project, these include hosting service providers, IT service providers, development service providers and development cooperation partners.
Insofar as you require further information on the recipients in the case of specific test drives, you are welcome to contact ALPS ALPINE EUROPE in accordance with the contact details provided.
A data transfer to third countries outside the EU, for which no adequacy decision of the EU Commission has been issued, only takes place insofar as appropriate guarantees for the protection of the data have been made. These include measures such as the conclusion of so-called EU standard data protection clauses (including transfer impact assessment) to protect your personal data.
F. Duration of processing and deletion of data
What is not needed must be securely destroyed.
ALPS ALPINE EUROPE will not retain traffic and environmental data for longer than a maximum of 10 years, during which time it may be reused for the lifetime of the components to test new software versions.
Storage beyond this period may be necessary for the purpose of asserting or defending legal claims. In each case, your data will be deleted no later than the expiry of the applicable limitation periods.
G. Your rights
1. Right to information (Art 15 GDPR)
If you so wish, we will be happy to inform you of the extent to which we process personal data relating to you. If processing takes place by us, we can provide you with the following information upon request:
- The purposes for which the personal data is processed;
- the categories of personal data which are processed; and
- the recipients or categories of recipients to whom the personal data relating to you have been or will be disclosed;
- the planned duration of the storage of the personal data relating to you or, if specific information on this is not possible, criteria for determining the storage period;
- the existence of a right to obtain the rectification or erasure of personal data concerning you, a right to obtain the restriction of processing by the controller or a right to object to such processing;
- the existence of a right of appeal to a supervisory authority;
- any available information on the origin of the data if the personal data is not collected from the data subject;
- the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information on whether the personal data concerning you are transferred to a third country or to an international organisation and to what extent appropriate safeguards pursuant to Article 46 of the GDPR are in place.
You have the right to obtain a copy of the personal data that is the subject of the processing. For any further copies you request, we may charge a reasonable fee based on the administrative costs. If you make the request electronically, the information must be provided in a commonly used electronic format unless you specify otherwise.
The right to receive a copy shall not prejudice the rights and freedoms of other persons and the right of access shall not apply to the extent that the access would disclose information which by law or by its nature must be kept secret, in particular because of the overriding legitimate interests of a third party.
2. Right to rectification (Art. 16, 19 GDPR)
Upon your request, we will promptly correct and complete the personal data we hold about you if it is incomplete.
We will forward your request to any recipient to whom the personal data has been disclosed, unless this proves impossible or requires a disproportionate effort, and will inform you of these recipients upon request.
3. Right to erasure ("right to be forgotten") (Art. 17, 19 GDPR)
You may request that we delete personal data relating to you without undue delay and we are obliged to delete such data without undue delay if one of the following reasons applies:
- The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.
- You withdraw your consent on which the processing was based pursuant to Art. 6 (1) a) GDPR or Art. 9 (2) a) GDPR and there is no other legal basis for the processing.
- You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.
- We have unlawfully processed the personal data concerning you.
- The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which we are subject.
- The personal data concerning you has been collected in relation to information society services offered in accordance with Article 8(1) GDPR.
We will forward your request to any recipient to whom the personal data has been disclosed, unless this proves impossible or requires a disproportionate effort, and will inform you of these recipients at your request.
Please note that a right to erasure does not exist insofar as we are legally obliged to process it or the processing of personal data is necessary for us to assert, exercise or defend legal claims.
4. Right to restriction of processing (Art. 18, 19 GDPR)
Furthermore, you may request the restriction of the processing of personal data concerning you under the following conditions:
- if you dispute the accuracy of the personal data relating to you for a period of time that allows us to verify the accuracy of the personal data;
- the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
- we no longer need the personal data for the purposes of processing, but you need them for the assertion, exercise or defence of legal claims; or
- if you have objected to the processing pursuant to Article 21 (1) GDPR and it has not yet been determined whether our legitimate grounds override your interests.

If the processing of personal data relating to you has been restricted, such data may - apart from being stored - only be processed with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by us before the restriction is lifted.
We will forward your request to any recipient to whom the personal data has been disclosed, unless this proves impossible or requires a disproportionate effort, and will inform you of these recipients at your request.
5. Right to data portability (Art. 20 GDPR)
Under the conditions of Art. 20 (1) GDPR, i.e. that
- the processing is based on consent pursuant to Art. 6 para. 1 a) GDPR or Art. 9 para. 2 a) GDPR or on a contract pursuant to Art. 6 para. 1 b) GDPR and
- the processing is carried out with the aid of automated procedures, and
- the freedoms and rights of other persons are not adversely affected thereby, and
at your request, we will transfer your personal data to you or another controller (where technically feasible) in a structured, commonly used and machine-readable format.
6. Right to object (Art. 21 GDPR)
Insofar as processing by us is based on Art. 6 (1) f) GDPR, you have the right to object to the processing of personal data concerning you at any time for reasons arising from your particular situation.
This also applies to profiling based on these legal grounds. We will then no longer process the personal data relating to you unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

At your request, your personal data will be deleted, in accordance with your right to erasure and subject to the conditions as explained above.
7. Right to withdraw consent (Art. 6 (1) a), 7 GDPR)
In the event that processing by us is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal.
8. Automated decision-making in individual cases including profiling
No automated decision-making, including profiling, takes place in the course of traffic and environmental data collection through video data recording in the context of test drives.
9. Right to lodge a complaint with the supervisory authority (Art. 77 GDPR)
If you consider that ALPS ALPINE EUROPE has breached its obligations under the General Data Protection Regulation or the national data protection legislation applicable to you, in addition to national remedies, you have the right to lodge a complaint with a supervisory authority, in particular at your habitual residence, place of work or the place of the alleged breach.
10. Consequences of not providing data
Of course, you are under no legal or contractual obligation to provide us with your data. However, we ask for your understanding that it is impossible to develop efficient and safe comfort- and safety-related electronics and software without using real traffic and environmental data for this purpose.
H. Contact details of the data protection officer
You can reach our data protection officer by post at Ohmstr. 4, 85716 Unterschleißheim and by e-mail at datenschutz.eu@alpsalpine.com.