Privacy Policy for Road Test

This Privacy Policy is and explanation by DENSO Corporation, on behalf of itself and its subsidiaries in the European Economic Area (the “Company”) to person who resides in the European Economic Area protected under the General Data Protection Regulation No 2016/679 (the “GDPR”) regarding how we collect and process personal data the Company acquires in the course of public road tests (“Personal Data”) as a data controller.

1. Personal Data to Be Processed

The Company processes (meaning any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, and such operation means acquisition, recording, organization, structuring, storage, rectification, alteration, recovery, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction; hereinafter the same) the Personal Data, including but not limited to the following information.

physical data such as facial image of pedestrians, license plate number, etc.

The Company records pedestrians and license plates in a purely random manner without any intent to identify the specific natural persons.

2. Purpose of Use of Personal Data and Legal Basis

The Company processes the Personal Data to accomplish the following purpose.

Purpose: Planning, evaluation, research, development, manufacturing, and quality assurance of the Company’s current and future advanced drive assistance system products and service. The Company’s products are here. 

Legal basis: Legitimate interests in development of Company’s current and future products, as long as this is carried out in compliance with data protection regulations. Developing advanced drive assistance system products and service will aid in the prevention of damage to vehicles, such as by automatically detecting obstacles and provide more comfortable and convenient future mobility.

If the Company processes the Personal Data for any other purpose than the abovementioned purposes, the Company will notify the additional purposes of use and other matters necessary under the laws in advance and get consent of the user.

The Company promptly erases the Personal Data if it is no longer necessary for the abovementioned Purposes.

3. Provision to Third Party

The Company shall provide subsidiary and affiliate of the Company and its subcontractor with the Personal Data for the purpose of accomplishing the purposes of use specified above.

A third party to whom the Company provides the Personal Data includes a party located in a country outside the EU (including, but not limited to, Japan, United States and Vietnam; hereinafter the same). Please note that such countries may not have the same data protection laws as the EEA and that they may not afford many of the rights conferred upon you in the EEA.

Further, the Company guarantees that adequate measures are ensured with respect to the protection of Personal Data, such as by entering into SCC in accordance with the GDPR, when providing a third party located in a country outside the EU with the Personal Data.

4. Ensuring of Accuracy

The Company endeavors to keep the Personal Data up to date and if it is inaccurate or insufficient, rectify it.

5. Security

To prevent unauthorized access to Personal Data or divulgence of Personal Data, the Company evaluates and determines the risk of breach of the Personal Data privacy in a comprehensive manner after taking into account the category of Personal Data, degree of sensitivity, influence including economic and mental damage to you when the Personal Data privacy is breached, and takes personnel, organizational and technical safety management measures that are necessary and appropriate according to the risk of breach of Personal Data privacy, set the process to inspect and correct such safety management measures as necessary and makes ceaseless efforts to improve security.

6. Data subject’s rights

You may request the Company make your Personal Data retained by the Company available to you, rectify, erase or restrict the processing of such information or take procedures for data portability.  Further, you have the right to raise an objection to the Company or data protection authority governing the location where you reside with respect to the processing of the Personal Data.  If you require the procedures for exercising various types of rights granted to you with respect to the Personal Data, please contact us at the following contact information in the Section 8.

Please note that the Company records pedestrians and license plates in a purely random manner without any intent to identify the specific natural persons. Therefore, we need to know additional information (such as the exact time, date and place of the video recording) in order to respond to your requests.

7. Amendment to Privacy Policy

The Company may amend the privacy policy at any time and the amended privacy policy shall become effective when the period of 2 weeks set aside to publicize the amendment ends.

8. Inquiries

If the user has any matter for consultation or question with respect to the privacy policy or the processing of the Personal Data by the Company, please contact us at the following contact information.

Contact information:
DENSO Europe B.V.

E-mail address: privacy@denso.nl