Product Development and Testing
Below, we inform you about the processing of your personal data by AUDI AG in connection with the use of test vehicles on public roads. AUDI AG makes use of so-called test vehicles for the purposes of development, testing and safeguarding. These vehicles are equipped with sensors and measuring instruments as well as video measurement technology indicated on the body.
Personal data includes all information related to an identified or identifiable natural person. A natural person can be considered an identifiable natural person when identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Processing means any performed operation or set of operations, which may or may not be performed with assistance of automated processes, based on personal data or on sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
1. Who is responsible for data processing and whom can I contact about this?
The data controller for the processing of your personal data is:
AUDI AG, Auto-Union-Straße 1, 85045 Ingolstadt, Germany.
If you have any concerns about data protection, you may also contact our company data protection officer:
AUDI AG, Datenschutzbeauftragter, Auto-Union-Straße 1, D-85045 Ingolstadt,
2. What data does AUDI AG process and what sources does it come from?
The measurement technology built into the test vehicles processes e.g. video images from outwardly directed cameras. The cameras process real-time images of the public traffic, e.g. license plates and individuals. This information also includes personal data about you. This personal data (hereinafter referred to as “Data”) comprises:
- Photographic images of you
- Vehicle license plates
3. For what purposes and on what legal basis does AUDI AG process your data?
AUDI AG processes your personal data based on the balancing of interests as per Art. 6 para. 1 subsection 1 letter f) of the EU General Data Protection Regulation (GDPR) exclusively for development, testing and trial purposes and in connection with quality assurance measures (necessary trials, for safeguarding). Any other use is precluded. The legitimate interest of AUDI AG lies predominantly in the development and safeguarding of safety-related driving functions such as driver assistance systems and highly and fully automated driving. Other legitimate interests are the intention to improve product, vehicle and road safety and to reduce the number of accidents.
4. Who gets my data?
Due to the size and complexity of data processing at AUDI AG, it is not possible to individually list every recipient of your personal data in this data protection notice, which is why only categories of recipients will be listed.
Within AUDI AG, only the departments that need your data as part of their activities will receive your data (e.g. Product Development in Technical Development).
Service providers hired by AUDI AG (so-called “contract processors”) may also receive data for these purposes. These include:
- Companies within the VW Group that provide services (e.g. IT services) for AUDI AG (VW AG),
- Print service providers,
- Archiving service providers,
- Hosting service providers,
- IT service providers.
In addition, AUDI AG provides your personal data to the following recipients and/or recipient categories, who act as data controllers:
- Companies belonging to the Audi Group,
- companies belonging to the VW Group,
- service providers,
- development partners and
who are each involved in product development, testing and analysis. AUDI AG will be happy to provide you with further information on the recipients in the case of specific test drives. Please use the contact data provided below.
5. Is data transferred to third countries?
Insofar as recipients are located in a country outside the European Union or outside the European Economic Zone (so-called third-party countries), the data may be communicated to a country in which there is possibly no appropriate level of data protection, i.e. one that is not comparable with the level in the EU.
Please note that not all third-party countries have a level of data protection considered adequate by the European Commission. For data transfers to third-party countries where there is not an adequate level of data protection, AUDI AG has taken appropriate steps, e.g. put standard data protection clauses in place to protect your personal data. You are entitled to receive a copy of these steps. Please use the contact information listed below.
6. How long is my data stored?
The data collected within the context of the use of the test vehicle is stored for as long as it is necessary for testing and trial purposes and in connection with quality assurance measures, including long-term monitoring and development purposes.
7. What rights do I have?
|As a data subject, you are entitled to the following data protection rights:|
|Disclosure||You have the right to request information about the data stored about you by AUDI AG and the scope of the data processing and forwarding carried out by AUDI AG, and to receive a copy of the personal data stored about you.|
|Rectification||You have the right to request immediate rectification of personal data related to you that is incorrect as well as to the completion of incomplete personal data that AUDI AG has stored of you.|
|Deletion||You have the right to request immediate deletion of your personal data stored by AUDI AG, presupposed that there are no legitimate reasons for the continued storage of that data.|
Under certain conditions, you have the right to request the restricted processing of your personal data (i.e. the designation of stored personal data with the aim of limiting future processing). These conditions are:
- The accuracy of the personal data is disputed by you and AUDI AG must review the accuracy of the personal data;
- The processing is illegitimate, but you reject the deletion of your personal data and request restricted use instead;
- AUDI AG no longer needs your personal data for processing purposes, but you need the data to establish, exercise or defend legal claims;
- You have objected to the processing of your personal data, but it is still not clarified whether the legitimate interests of AUDI AG outweigh your interests.
If processing is restricted, aside from being stored, your personal data is only allowed to be processed with your consent or for the establishment, exercise or defense of legal claims or to protect the rights of another natural person or legal entity or for reasons of an important public interest of the EU or an EU member state.
|Data portability||If your personal data, that you have provided us on basis of your consent or a contract (including your employment contract) is processed by us in an automated manner, you have the right to receive the data in a structured, standard and machine-readable format, and to transmit this data to another data controller without being prevented from doing so by AUDI AG. You also have the right to have the personal data transferred directly by AUDI AG to another data controller if this is technically feasible and the rights and freedoms of other persons are not affected by this.|
|Objection||If we process your personal data on the grounds of legitimate interests or in the public interest, you have the right to object to such processing on personal grounds. Please see our separate note on this in the section entitled “Information on your right to object.” (eighth point).|
|Withdrawal of consent||If you have granted consent for the processing of your personal data, you may revoke this consent at any time. Please note that your withdrawal of consent only applies to future processing. Any processing carried out before consent is withdrawn remains unaffected by the withdrawal.|
You also have the right to lodge a complaint with a data protection supervisory authority if you believe that your personal data is processed illegitimate. You have the right to lodge such a complaint irrespective of any other administrative or judicial remedies. The address of the data protection supervisory authority responsible for AUDI AG is:
Bayerisches Landesamt fuer Datenschutzaufsicht (BayLDA)
Please note that AUDI AG generally only processes the real-time images of public traffic recorded by the cameras of the test vehicle in order to record the vehicle environment with the aim of identifying obstacles and other traffic participants and effectively preventing accidents. The use of such technology is technically necessary to enable (semi-)autonomous driving. In the case of test vehicles, the images are used solely to develop the vehicle systems to the point where they are market ready. Thus, in general it is not possible for AUDI AG to identify the individuals and vehicles filmed, nor is that the intention. In these cases, AUDI AG is not obligated, where relevant, to fulfill your rights of disclosure, rectification, deletion, restricted processing, data portability and contradiction. If identification is not possible, we will notify you of this. In such a case, you have the possibility to provide AUDI AG with additional information that enables you to be identified (e.g. information about your appearance and clothing at the time the image was taken, the location, time and date of the contact with the test vehicle, vehicle registration number or at least the model and color of the test vehicle). If, with the aid of this additional information, we succeed in identifying you, we will, of course, fulfill your rights within the scope of our obligations under the GDPR.
8. Information about your right to object
Right to object for personal reasons
You have the right, for reasons arising from your specific situation, to object to the processing of your personal data. The requirement for this is that the data processing is done in the public interest or done with the intention of balancing interests. The same shall apply to profiling.
Insofar as AUDI AG bases the processing of your personal data on a balancing of interests, AUDI AG works on the assumption that compelling legitimate reasons can be demonstrated. However, AUDI AG examines each individual case, of course.
In the case of an objection AUDI AG will no longer process your personal data, unless
- AUDI AG can prove compelling legitimate grounds for the processing of the data that outweigh your interests, rights and freedoms, or
- your personal data serves to establish, exercise or defend any legal claims.
Exercising the right to object
The objection can be made informally and, where possible, should be sent using the contact information provided in this data protection notification.
Should you have any questions about this data protection note or on the processing of your personal data by AUDI AG or wish to exercise your data protection rights, please use the following contact address:
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