This Information on Personal Data Processing contains information on the collection, processing and usage of your personal data by
ŠKODA AUTO a.s.
tř. Václava Klementa 869
Mladá Boleslav II, 293 01 Mladá Boleslav
CZECH REPUBLIC
infoline@skoda-auto.cz
entered in the register of companies at Municipal Court in Prague under the register No. B 332 (ŠKODA) for the activation of data transmission for the purposes of building an anonymous database for research and development of automated driving.
The upload function is used for collecting measurement data recorded by vehicle sensors. The measurement data is sent to a data server (see below, A.V.1. Data servers), immediately anonymised and used by ŠKODA and its partners to research and develop automated driving.
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 determine 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 ŠKODA on the basis of contractual principles which include appropriate data protection guarantees. These partners may also use the data in order to research and develop the 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 data is stored there for a maximum of twenty-four (24) hours for anonymisation and quality assurance purposes. The original data is then completely deleted from the vehicle. 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.
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 GDPR). 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 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, ŠKODA has a legitimate interest in the processing of data and building an anonymous database.
Data transmission is not activated ex works and only begins when an active “ŠKODA 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. In some models, data upload is activated or deactivated using the "Send Location Data" slider in the privacy settings.
If a user settings change is made in the vehicle from a user with the activated function "Development of automated driving" to a user with this function deactivated, ŠKODA UserID and VIN may be transferred to ŠKODA on a one-time basis. This is based on ŠKODA's legitimate interest (Article 6, paragraph 1, letter f) GDPR). Transferred data will not be saved.
The data is processed on the following service providers’ servers only on our behalf and in accordance with our instructions:
CARIAD SE
Berliner Ring 2
38440 WOLFSBURG
GERMANY
Volkswagen AG
Berliner Ring 2
38440 Wolfsburg
GERMANY
Audi AG
Auto-Union-Strasse 1
85057 INGOLSTADT
GERMANY
Microsoft Corporation
One Microsoft Way
Redmond, WA 98052-6399
USA
At Microsoft Corporation, the data is encrypted according to agreements made with us and exclusively processed on data servers in the European Union. As Microsoft Corporation is based in the United States, (read) access to data from the United States cannot be ruled out. Corresponding EU standard contractual clauses for the transmission of personal data to processors in third countries were concluded to ensure sufficient protection of your personal data. The EU standard contractual clauses used can be found on the European Commission’s website at the URL https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32010D0087.
We also use an IT service provider. This service provider helps us, for instance, with the maintenance of our IT systems and technical support. If the service provider gains access to your personal data, it will process this only on our behalf and in accordance with our instructions.
Volkswagen Group Service
Bunsenstraße 5
85053 Ingolstadt
GERMANY
diconium digital solutions GmbH
Rommelstraße 11
70376 Stuttgart
GERMANY
You may assert the following rights vis-à-vis ŠKODA at any time free of charge. This also applies insofar as we are jointly responsible with other companies for data processing. More information on exercising your rights can be found on the website https://www.skoda-auto.com/other/personal-data.
You have the right to obtain confirmation from us as to whether, and if so, which, personal data concerning you is being processed and to which third parties within and outside the EU your data has been disclosed. Furthermore, you have the right to receive a copy of your personal data which has been processed by us.
You have the right to request that we rectify any of your personal data that is incorrect or incomplete.
You have the right, in the event that the requirements specified in Article 17 GDPR have been met, to request the erasure of your data. Accordingly, you may request the erasure of your data, for instance, if it is no longer necessary for the purposes for which it was collected. Furthermore, you can also request erasure if we process your data on the basis of your consent and you revoke this consent.
You have the right to request the restriction of the processing of your personal data if the requirements specified under Article 18 GDPR have been met. This is the case, for example, if you dispute the accuracy of your data. You may then request that processing is restricted for as long as it takes to examine the accuracy of your data.
You have the right to object to the processing of your data in the following cases:
• If the processing is for direct marketing purposes (including profiling for direct marketing purposes).
• If the processing (including profiling) is based on the following legal grounds:
o The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us (Article 6, paragraph 1, letter e GDPR).
o The processing is necessary to safeguard the legitimate interests of us or of a third party (Article 6, paragraph 1, letter f GDPR) and we are not in a position to demonstrate compelling reasons for processing worthy of protection which outweigh your interests, rights and freedoms or the processing serves to assert, exercise or defend legal claims. In the event of such objection, you are kindly requested to notify us of your reasons for objecting to data processing.
Provided that the data processing is based on consent or on the fulfilment of a contract and that it is also carried out using automated processing, you have the right to receive your data in a structured, common and machine-readable format and to forward it to another responsible party. In addition, you have the right to request that the personal data be forwarded directly from us to another responsible party.
If the data processing is based on consent, you have the right to revoke your consent at any time free of charge with effect for the future by email to dpo@skoda-auto.cz or via the contact details in the site notice.
You also have the right to complain to a supervisory authority (e.g. the Czech Office for personal data protection or the supervisory authority responsible at your place of residence) about our processing of your data.
For information on your points of contact for the exercise of your rights and further information, please visit the following link https://www.skoda-auto.com/other/personal-data.
Our data protection officer is your point of contact for issues related to data protection:
ŠKODA AUTO a.s.
Data Protection Office
tř. Václava Klementa 869
Mladá Boleslav II, 293 01 Mladá Boleslav
CZECH REPUBLIC
dpo@skoda-auto.cz