1 Privacy Policy related to test drives for research and development purposes

Mitsubishi Electric Automotive Europe B.V., together with other members of its group (MEAE, we/us/our) are committed to safeguarding the privacy of personal data. This privacy policy describes how MEAE uses and discloses the information (personal data) collected and processed in relation to drives for research and development purposes.

2 Information we may collect about you

In the framework of above-mentioned purpose (research and development) marked test vehicles are operating on public road and collect data.

These test vehicles may collect data using:

• Video cameras
• GPS localization, including time stamp
• Vehicle speed
• Various sensors (such as radar, lidar)
• Microphones

During these test drives, the devices might capture personal data such as faces and license plates. However, we are not interested in identifying individuals, vehicle models or drivers as this is not necessary for our purpose. Data are blurred as soon as possible and to the extent possible, resulting in anonymized data that cannot be directly traced back to the individual.

3 Uses made of your personal information.

In this section, we set out the purposes for which we use personal information that we collect and, in compliance with our obligations under European law, identify the “legal grounds” on which we rely to process the information.

These “legal grounds” are set out in European Data Protection Law, which allows companies to process personal data only when the processing is permitted by the specific “legal grounds” set out in law.

3.1 For research and development purposes
As written before, the data is normally anonymized. In exceptional cases where personal data does remain, we have the following legal grounds.

According to Art. 6 sec. 1 lit. f) GDPR we have a legitimate interest in processing your personal information for the purpose of improving and developing our ADAS (Automatic Driving Assistance System), automated driving, systems and other services improving vehicle safety, comfort and reduce the risk of accidents. We also process this data in order to pursue our legitimate interests in ensuring the compliance of our products with technical requirements and specifications or with safety requirements, improving our products including assessing their performance and reliability in real-life environments.

Our test drives serve the improvement of traffic safety and are in the public interest.

4 Storage and security

We will share personal data only with MEAE group companies and cooperation partners for the above mentioned purposes. We will disclose personal data to other third parties only if it is permitted by law and/or by official or court order or if the third party has a legitimate interest.

Third parties that may have a legitimate interest could be in particular:

• Internal and external cooperation partners of MEAE for research and development purposes
• Suppliers for research and development purposes

5 Retention of the data

We keep your personal information for as long as is reasonably necessary to fulfil the purposes for which we collected it and to comply with our legal obligations.

In particular, the video, image and audio data are stored for the duration of the aforementioned research, development and testing purpose.

In some cases, statutory legal provisions (e.g. product liability) may require us to store data for a longer period of time.

6 Your rights & contacting us

According to the applicable data protection laws, you have the right to:

• request a confirmation whether MEAE processes your personal data and access to any of your personal data processed by us as well as further information,
• request the rectification of incorrect personal data,
• request the erasure of your personal data processed by us,
• request a restriction of processing of your personal data from us,
• request to receive personal data provided by you in a structured, commonly used and machine-readable format or request that this data be transferred to a third party, or
• object to the processing of your personal data by us.

6.1 Information on your rights to object
Right to object on a case-by-case basis

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6 (1) (e) GDPR (data processing in the public interest) and Article 6 (1) (f) GDPR (data processing on the basis of a balance of interests). Should you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or which serve the establishment, exercise or defense of legal claims.

7 Recipient of an objection

The objection is not subject to any formal requirements and should be addressed to:

Mitsubishi Electric Automotive Europe B.V.,

Capronilaan 34, 1119NS, Schiphol-Rijk, the Netherlands

E-mail: DMO@meae.mee.com

The MEAE data protection organization will assist you with any questions concerning data protection. Complaints may also be made to the MEAE data protection organization and the rights mentioned before may be asserted. You can contact the data protection organization at:

E-mail: DMO@meae.mee.com

This Privacy Policy was last updated on 24-02-2023.