DRIVEN BASE

DENSO INTERNATIONAL ASIA AND DENSO CORPORATION Joint Privacy Notice for Data Collection Through On-Board Cameras

This Privacy Notice describes how we, as joint controllers, process your personal data, in particular within the meaning of the Personal Data Protection Act ("PDPA") in the event that one of our vehicles collects your personal data as part of our project to develop services that improve road safety for drivers ("Project").

This Privacy Notice was last updated on August 1, 2024

1. Controller, Representative

The controllers that are responsible for processing your personal data are:

DENSO INTERNATIONAL ASIA CO., LTD.
888 Moo 1 Bangna-Trad Rd. KM.27.5, T.Bangbo, A Bangbo, Samutprakarn 10560 Thailand (“DIAT”)
Email: ap_diat_dpocenter@ap.denso.com
and

DENSO CORPORATION
1-1 Showa-cho, Kariya-shi, Aichi, 448-8661 Japan (“DENSO”)
https://contact-us.denso.com/form/global/en/contact-us/privacy-policy
(both together as "we" or "us" or "our").

2. Categories of personal data, processing purposes, legal basis and source

If you encounter one of our vehicles engaged in the Project, it may collect the following personal data about you: location; video; electronic or visual information such as if applicable, the number on the license plate of the car you are driving, age, gender etc.

It is not intended to process sensitive personal data. However, the data collected while filming the surroundings may include special categories of personal data such as facial features, ethnic origin, political opinions, religious or philosophical beliefs, data concerning health (disability, wearing glasses), sexual orientation, if any of these are visible.

We process such personal data for the following purposes:

• The overall purpose is to increase road safety by reducing the risk of traffic accidents.
• We also develop and improve services which are developed based on the image recognition algorithms.

The legal basis for the processing of such personal data is Section 24 (5) of the PDPA. Our legitimate interest is to validate and improve the functionality of services to avoid traffic accidents by improving safe driving skills of drivers.

The data are stored on the servers of the data controllers in Japan in different types of formats: as encoded data, decoded original data (i.e. raw data) and blurred data. The raw data is used for AI processing except in cases where engineers need to perform safety checks, so that natural persons (engineers) who work on the Project basically access blurred data only.

The data are stored on the server in an area accessible only to a limited number of authorized, and access logs are collected to prevent them from being taken out illegally.

We will implement thorough organizational and technical information security measures in accordance with our Information Security Regulations and other regulations to prevent leakage, unauthorized use, and other incidents.

3. What rights do you have and how can you exercise your rights?

You may have the right to: request access to your personal data, request rectifications to your personal data; request erasure of your personal data; request restriction of processing of your personal data; and object to the processing of your personal data.

Please note that these rights might be limited under the applicable national data protection law and that we do not intend to identify you and may not be able to identify you. To learn more about these rights, please click on this link or scroll down to the Exhibit - Your Rights. Refer to section 1, above, to contact us to exercise your rights.
You may also have the right to lodge a complaint with a data protection supervisory authority.

4. How long do we keep your personal data

Your personal data will be retained for 7-10 years, as long as necessary in order to (i) develop services and improve it after the launch and to (ii) use the data for updates of services.

5. Automated Decision Making

We do not engage in automated decision-making in the context of the Project.

Exhibit

Your Rights

1. Right of access

You may have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data.

The access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. However, this is not an absolute right, and the interests of other individuals may restrict your right of access.

You may have the right to obtain a copy of the personal data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.

2. Right to rectification

You may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

3. Right to request erasure ("right to be forgotten")

Under certain circumstances, you may have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.

4. Right to restriction of processing

Under certain circumstances, you may have the right to obtain from us restriction of processing your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.

5. Right to object

Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data.

Contact

When you wish to exercise your rights, you can send a request
to ap_diat_dpocenter@ap.denso.com.

You can also contact us if you have any questions, comments or complaints regarding this Privacy Notice.

You can also file a complaint with the competent Data Protection Authority.