PRIVACY POLICY DATA COLLECTION FOR THE BUILDING OF AN ANONYMOUS DATABASE FOR THE RESEARCH AND DEVELOPMENT OF AUTOMATED DRIVING

In this privacy policy, we inform you about the collection, processing and use of your personal data by SEAT, S.A. (hereinafter, “SEAT”) in relation to the activation of data transmission for the building of an anonymous database for research and development of automated driving.

Who is the data controller of your personal data?

How do we use your personal data?

The upload function is used for collecting measurement data recorded by vehicle sensors. The measurement data is sent to a data server immediately anonymised and used by SEAT and its partners for the research and development of automated driving.

Data transmission is not activated ex works and only begins when an active SEAT CONNECT primary user is logged in. The data upload can be directly activated or deactivated using the ‘Automated driving development’ slider in the privacy settings. Data transmission also depends on the setting of privacy levels. The upload is only active in the ‘Use location’ and ‘Share location’ levels.

The measurement data consists of two data groups:

a) Data which is relevant for reconstructing the factors which influence the vehicle:

• Vehicle position and timestamp:

  • Vehicle position.

  • Time of measurement.

  • Relative motion data (e.g. wheel rotations, steering angle, speed and acceleration of the vehicle).

  • Drive data which is relevant to vehicle motion (e.g. engine drive torque, rpm, braking interventions).

• Sensor recording of the immediate environment using the following sensors:

  • Camera sensors (e.g. detected signs, lanes, static and dynamic objects (but no image or video data)).

  • Radar sensors (e.g. static reflections of objects, detected dynamic objects).

  • Ultrasound sensors (e.g. side distance from surrounding objects).

  • Climate, rain, light (e.g. temperature, rain conditions, light influx).

• Detected traffic situations:

  • Local hazard spots (e.g. traffic jams, accidents, breakdowns).

  • Road conditions (e.g. friction, course of the road).

b) Data which is relevant to determining how the driver prefers to control the vehicle:

• Detected driver behaviour:

  • Driver’s control movements (e.g. steering movements, brake, accelerator).

  • Use of vehicle systems which affect the course of travel (e.g. gear shifts, operating driver assist systems, operating safety systems)

  • Status of and interventions from driving assistance functions (e.g. interventions from cruise control systems, triggered emergency braking, park assist systems)

Only data required for research and development of functions for partly and fully automated driving is collected. The anonymised measurement data is also supplied to partners of Volkswagen on the basis of contractual principles which include appropriate data protection guarantees. These partners shall also use the data anonymised for the purposes of researching and developing of automated driving.

On the basis of this data, a simulation environment is created which enables the testing of future automated driving functions in realistic conditions and can be compared in the outcome with the real driver’s preferred behaviour. As several billions of test kilometres are required to conclusively safeguard automated driving, this database needs to be filled with real data. This is the only way to ensure that all varieties of traffic situations can be recorded sufficiently to ensure that future automated driving functions are robust and safe enough to always make the right decisions and protect the safety of vehicle occupants.

The data sent to the data server once collected is quality controlled and then immediately anonymised in the data server. The anonymisation procedure is reviewed for efficiency and effectiveness and developed on an ongoing basis taking into account the latest scientific knowledge and the state of the art.

What is the lawful basis for processing your personal data?

The legal basis for the collection of data for extracting data from the vehicle is a consideration of interests (Article 6, paragraph 1, letter f of the General Personal Data Regulation).

The aims stated above for the research, development and safeguarding of automated driving functions can only be achieved by means of a significant data base from the widest possible variety of traffic scenarios based on real journeys. Classic endurance testing is no longer sufficient at this point. The data must consist of as many different driving scenarios as possible, whose environmental and traffic situations can only be recorded in the algorithms in real road traffic. Buying in data is also not sufficient at this point as the data is not available in the required quality and becomes obsolete even after a very short period of time. On these grounds, SEAT has a legitimate interest in the processing of data and building an anonymous database.

What other recipients will the data be disclosed to?

SEAT does not disclose your personal data unless in order to comply with legal obligations.

On the other hand, SEAT will give access to data to third parties acting as data processors for the purpose of anonymizing the data and acting only on our behalf and in accordance with our instructions. Volkswagen AG is our service provider for anonymising the data, which in turn hires other service providers such as AUDI AG and CARIAD SE to carry out this anonymisation service, with all of them acting as subprocessors. The data is encrypted in accordance with the agreements made with Volkswagen and exclusively processed on data servers in the EU. Some of these service providers may be located in the United States, therefore access to data from the United States cannot be ruled out.

A corresponding EU standard data protection agreement (adequate guarantee for data processing in non-European countries) has been concluded to ensure sufficient protection of your personal data. You have the right to be informed of the standard data protection agreement in the course of disclosure.

How long do we retain your personal data?

The data is stored there for a maximum of 24 hours for anonymisation and quality assurance purposes. Therefore, the original data is then completely deleted from the vehicle.

What are your rights as affected individual?

If you consider that SEAT has not processed your personal data in accordance with the applicable regulations, you can file a complaint before the competent control authority through the website www.aepd.es

The exercise of these rights is free of charge.