Test Vehicles Privacy Policy
Data Processing connected to test vehicles
An important enabler in our mission to develop mobility solutions for a different tomorrow is to be able to enhance a comfortable and safe driving and riding experience by the development of assisted, connected and automated functions for the vehicle.
For this reason, we use properly marked test vehicles with sensors and cameras to register data that will allow further development and tuning of the equipment needed for autonomous functions.
Any long-lasting relationship is built on respect and trust;therefore, the privacy and integrity of your personal data is of the utmost importance to our company.
Which entity is responsible for data processing?
Zeekr Technology Europe AB, org. no 556922-7639, registered office at Pumpgatan 1, 417 55 Gothenburg (hereinafter referred to as "Zeekr Tech EU"), is the controller as defined by the General Data Protection Regulation (hereinafter referred to as "GDPR"), the Swiss Federal Act on Data Protection and the Norwegian Personal Data Act and is responsible for processing data as Data Controller for video and audio recordings. If you are a resident of Switzerland or Norway, please scroll to the bottom of this privacy policy for information on its applicability.
Which data do we process and what do we use it for?
At Zeekr Tech EU we focus strongly on the safety of our vehicles and one of the features that we are constantly working on for a safer performance is Advanced Driving Assistance Systems (ADAS). ADAS functionalities are heavily data dependent and therefore we have equipped our vehicles with sensors like cameras, radars and lidars to collect data.
These sensors capture environmental information. Data such as images and video will be processed in the vehicle's “brain” and based on that, the car will actuate. External audio is in principle not recorded, except if it is necessary only to log issue descriptions in the interior of the vehicle. Receiving such information does not mean that we are interested in analysing any personal information.
The data we collect is to be used for the development of assisted, connected, partly automated, and autonomous driving functions and to that end, we collect data using the sensors mentioned above. During these tests, personal data relating to members of the public may be captured incidentally, including the below:
License plates
Images and video recordings
Other data captured incidentally by the vehicle sensors
To train the vehicle’s “brain” is a continuous development and testing iscarried out repeatedly. The “brain” is trained to find the static and dynamic traffic movements, pedestrians crossing the roads, bicyclists etc. At each stage where any new functionality is developed, the vehicles need to be driven on the road and tested. If anything unexpected happens, the collected data will be analysed for debugging purposes to improve the quality of the vehicle functionality, before it is verified again. This process will continue until the vehicles are proven safe enough to be delivered to our customers.
We care just as much about data privacy we do about safety and aim to limit the use of personal data as much as possible. That is why we have marked our test cars with labels with QR codes so that individuals will be able to contact Zeekr Tech EU to receive more information on the purpose and handling of the collected data, or to submit a request for data removal or exercise their other rights under privacy laws.
What is the legal basis for this data processing?
The legal basis for the collection and processing of these video and audio recordings of the surroundings of the test vehicles (including the recording of personal data such as video recordings of pedestrians, drivers) by us is the legitimate interest of Zeekr Tech EU pursuant to Art. 6 (1) lit. f GDPR.
Zeekr Tech EU's legitimate interest in the processing and storage of these video and audio recordings results from its interest in operating the test vehicles and in further developing the platform for assisted, connected, partly automated and autonomous driving for safety and enhancing the driving experience.
During the development process, the data collected by the test vehicles will be used to develop and validate the algorithms for different functions of automated driving.
Furthermore, there is also a legitimate interest in processing the data of the test vehicles after the start of production, which is particularly important (i) to develop/validate updates of the software ("bug fixing") and (ii) to establish a defense in case of litigation or (iii) to comply with legal obligations, in particular with regulatory requirements. In addition, Zeekr Tech EU has a keen interest in improving vehicle and road safety through the development of its driving systems, serving the interest of the general public.
The video and audio recordings of test vehicle surroundings are necessary to ensure the safe use of the assisted, connected, partly automated and autonomous vehicles.
How long do we store your data?
We store your personal data only as long as required for carrying out the intended purposes outlined above.
How do we store your data?
The following safeguards are used, for example, to protect your personal data from misuse and or any form of unauthorised processing:
Access to personal data is restricted to a limited number of authorised persons for the stated purposes.
The data collected is only transmitted and stored in an encrypted form.
The IT systems used are separated from other IT systems to prevent unauthorised access.
IT systems are constantly monitored to detect access and prevent misuse.
Personal data will be anonymised as soon as possible after collection.
With whom do we share data and how do we protect you?
Due to the massive complexity and the requirement to fulfil the highest standards of accuracy, extensive testing including millions of driving kilometers are needed to develop and tune the functions that will allow the assisted, connected and autonomous driving in our vehicle. Such an enormous undertaking to develop and tune both hardware & software for autonomous driving through data collection cannot be performed by our company alone. Therefore, we have established long-lasting cooperation with reliable partners, like suppliers (including development and technology service providers) to strengthen and refine this development.
The transfer of video and sensor data to our partners is subjected to the strict purpose of technical development. The personal data gathered during this development and testing phase will mainly be used to develop, validate and refine the hardware and software that will enable the autonomous drive operation of the vehicle including the software integration with the software from the rest of the vehicle. Data is shared where possible after it is properly anonymised.
Zeekr Tech EU and partners do not use collected data to identify individuals since this is not relevant to the main purpose of this data collection which is the development and refinement of functions (hardware and software) needed for assisted, connected and autonomous drive of our vehicles.
From the data collected the only distinction that will be made is to identify pedestrians as persons (as distinguished from other road users like cars and trucks) and their direction of movement.
For personal data transfers inside European Union, European Economic Area, or countries outside the EU that have comparable level of data protection such as Canada and Switzerland, Zeekr Tech EU makes use of Data Processing Agreements (DPAs).
If data is processed by one of our partners outside the European Union, Zeekr Tech EU uses European Standard Contractual Clauses (SCCs) in addition to DPAs to ensure that the data collected is handled and protected according to European data protection standards. For further details on how collected data is transferred and protected please contact us through the channels specified below.
Contact details
If you have any questions regarding the use of your personal data, please contact the Data Privacy Team at dataprivacy@zeekr.eu
Marking of the test vehicles
The test vehicles are marked with the following or similar stickers. The stickers are attached to the sides and in the rear of the vehicles.
Rights of the data subject
You have the right to exercise your rights as a Data subject. Such requests should be lodged to the Data Privacy Team at Zeekr Tech EU (see contact details below).
Zeekr Tech EU strives to limit the processing of personal data for our training. That means in certain situations, we may be unable to respond to your request as a data subject due to legal requirements or information available to us.
At Zeekr Tech EU we do not use facial recognition software. We may therefore not be able to retrieve images of recorded persons without additional information (such as time and place) since such identification is not necessary for the purposes pursued by Zeekr Tech EU, or Zeekr Tech EU are prevented by law from carrying out additional data processing for the purpose of identification; in such cases, your rights under Art. 15 to 20 GDPR may not be applicable.
Your data subject's rights may only apply if you provide us with additional information which enables us to clearly identify you. With additional information provided, we may not in some cases be able to verify your entitlement to access or delete the data, since we do not identify any persons on the video and audio recordings, and would therefore not know who the data subjects on the recordings are, and your data subject rights are restricted due to rights of others or the need to keep the data for reasons of law.
During and immediately after the data collection activities of the test vehicles (e.g. if you are an individual walking by within the camera’s view and you become aware of the recording), you can directly object and ask the test driver for the deletion of relevant data.
Right to access (Art. 15 GDPR):
You are entitled to obtain a confirmation from Zeekr Tech EU as to whether your Personal data are being processed by Zeekr Tech EU and, if so, access to the Personal data and the following information:
The categories of data we process, the purposes for which it is processed, the source of the data if not collected directly from you, and, if applicable, the recipients with whom we have shared your data. You can obtain a copy of your data from us free of charge. If you require multiple copies, we reserve the right to charge you for these copies.
Right to rectification (Art. 16 GDPR):
Zeekr Tech EU will take steps in accordance with the applicable legislation to keep your Personal data accurate, complete and up to date. If you identify that any Personal data related to you is inadequate, incomplete or incorrect, you are entitled to have the Personal data corrected.
Right to erasure (Art. 17 GDPR):
Under certain circumstances, such as when you have revoked your previously given consent and there is no other legal ground available for Zeekr Tech EU to process your Personal data, you may request to have your Personal data erased.
Right to restriction of processing (Art. 18 GDPR):
You are under certain circumstances entitled to restrict the processing of your Personal data to only comprise storage of the Personal data, e.g. during the time when Zeekr Tech EU assesses whether you are entitled to have Personal data erased in accordance with section Right to erasure.
Right to data portability (Art. 20 GDPR):
When Personal data is processed on the basis of your consent or on the basis that the processing is necessary in order to perform a contract with you, and provided that the Personal data have been provided by you, you are entitled to receive a copy of your Personal data in a common machine-readable format.
Right to object (Art. 21 GDPR):
If the processing of your Personal data is based on a balancing of interests and you deem that your integrity interest overrides Zeekr Tech EU 's legitimate interest to process your Personal data, you may, on grounds related to your particular situation, object to the processing by contacting Zeekr Tech EU on the contact details below, in which case Zeekr Tech EU must have a compelling reason in order to continue to process the Personal data for the relevant purpose.
Time limits for compliance with the rights of the data subject
We make every effort to comply with all requests within 30 days. However, this period may be extended for reasons relating to the specific right or complexity of your request.
Complaint to supervisory authorities
You are welcome to contact us with any enquiries and complaints that you may have regarding the processing of your Personal data. However, you also have the right to lodge complaints pertaining to the processing of your Personal data to the Swedish Supervisory Authority (Sw. Integritetsskyddsmyndigheten (IMY) or your local data protection authority.
Notice for residents of Switzerland
If you are in Switzerland, the Swiss Federal Act on Data Protection (FADP) is applicable to this data processing activity:
Data Processing Related to Test Vehicles
At Zeekr Technology Europe, our mission to develop advanced mobility solutions necessitates the enhancement of comfortable and safe driving experiences through the development of assisted, connected, and automated vehicle functions.
To achieve this, we utilize properly marked test vehicles equipped with sensors and cameras to collect data essential for the development and fine-tuning of autonomous functionalities.
We value the privacy and integrity of your personal data and are committed to processing it in compliance with the Swiss Federal Act on Data Protection (FADP).
Data Controller
Zeekr Technology Europe AB, org. no 556922-7639, with its registered office at Pumpgatan 1, 417 55 Gothenburg, is responsible for the processing of personal data collected through our test vehicles.
Purpose and Legal Basis for Data Processing
Our test vehicles are equipped with sensors such as cameras, radars, and lidars to collect environmental data, including images and sounds. This data is processed to develop and validate Advanced Driving Assistance Systems (ADAS) and autonomous driving functions.
While our primary focus is on environmental data, incidental capture of personal data (e.g., images of pedestrians or license plates) may occur. In such cases, processing is conducted in accordance with FADP requirements.
Data Subject Rights
Individuals whose personal data may be incidentally captured have rights under the FADP, including:
Right to Information: You can request information about the processing of your personal data.
Right to Rectification: If your data is inaccurate or incomplete, you have the right to request correction.
Right to Deletion: You can request the deletion of your personal data under certain conditions.
Right to Object: You have the right to object to the processing of your personal data.
To exercise these rights, please contact us at dataprivacy@zeekr.eu
Data Retention
Personal data is retained only as long as necessary to fulfill the purposes outlined or as required by law.
Data Security
We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, or misuse.
Notice for residents of Norway
If you are in Norway, this privacy policy will be applicable in the same way as under the EU GDPR, subject to Section 1 of the Personal Data Act of Norway.
Adress:
Zeekr Technology Europe AB
Pumpgatan 1,
417 55 Gothenburg Göteborg, Västra Götalands län
Telephone: +46 (0)31 309 75 70
Email: info@zeekrtech.eu
Zeekr Tech EU`s Data Privacy Team can be contacted on:
dataprivacy@zeekr.eu