We make use of test vehicles for the purposes of development, testing, validation, quality assurance and/or safeguarding.
Those vehicles are driven in test areas but also on public roads. They are equipped with sensors and measuring instruments as well as video measurement technology, and thus are inclined to film the surrounding of public roads. It could happen that your vehicle including its license plate or you as a road user (pedestrian, cyclist, motor rider, car driver, etc.) in the street might be filmed.
It is not our aim to identify persons or to collect personal data. In case it were possible to achieve that purpose, we would use blurring technologies.
Marking of the test vehicles
Our test vehicles are marked with the following or similar stickers.
Those stickers identify our test vehicles and indicate that they may record some videos of their immediate environment.
The following Privacy Notice wants to inform you what kind of personal data might be processed and to whom it might be disclosed and what kind of rights you have regarding Privacy.
Your personal data may be processed in connection with the use of test vehicles on public roads by FCA Italy S.p.A. AUTOMOBILES SA, located in Corso Agnelli 200, 10135, Torino, Italy, part of STELLANTIS Group, as controller, as follows.
The data processing is based on legitimate interest according to Art. 6 (1) 1 f) General Data Protection Regulation (GDPR) unless you have exercised your right to object (Art. 21 (1) GDPR).
FCA Italy S.p.A. (further named “we”) has the legitimate interest in improving its vehicles and road safety through the development of its driving assistance systems. This implies the processing and storage of videos, which are recorded by test vehicles.
Furthermore, we shall also be able to establish a defense in case of litigation.
What data do we process and what do we use it for?
We, as controller, process your personal data as follows:
The measurement technology built into the test vehicles processes e.g. videos from outwardly directed cameras. Those cameras collect real-time images of the public traffic. This information may also include personal data about you:
Videos of you, as road users (pedestrian, cyclist, motor rider, car driver, etc.),
Vehicles’ license plates,
GPS location of the test vehicle, at the moment of the measurement.
Our technical teams use these data in order to improve existing vehicle functions, or to develop new ones. We are not interested in determining the identity of an individual, and the measurement system is not configured for that purpose, as this is not necessary for the development of the automated driving platform. All traffic objects are only categorized as trucks, cars, motorcycles, pedestrians, etc.
In case it is possible, we use blurring technologies to ensure that potential personal data is not processed.
How long is data stored?
The abovementioned data are stored and processed for the needs of innovation projects, typically three (3) to five (5) years. For the development of some new driving assistance systems, we may be required to keep some cars’ data in archive databases for ten (10) years after the end of the model’s production, in case of litigation.
Who might receive data?
We disclose above-mentioned data for product and services optimization, development, test and validation of autonomous vehicle and driving assistance systems to the following recipients:
Due to the size and complexity of data processing, it is not possible to individually list every recipient of personal data in this privacy statement, which is why only categories of recipients will be listed here.
Within our legal entity, only the departments that need the data as part of their activities have access to the data, e.g. product development teams engaged in the development of driving assistance systems and autonomous driving in our technical centers.
FCA US LLC who is placed outside the European Economic Area (EEA) in U.S. as well as his engaged sub-processors, and therefore in a country without adequate level of data protection. There is no adequacy decision of the European Commission but there are appropriate safeguards in place, which are in this case EU Standard Contractual Clauses. In order to obtain a copy please send us an e-mail (see paragraph “Contacting us”).
We also disclose your personal data to our respective engaged IT service providers who act as processors to support the administration of the named purposes, in particular to archiving service providers, hosting service providers and/or IT service providers.
In addition, and especially for the development, test and/or validation of algorithms of new automated driving assistance systems and autonomous driving, and only when anonymization is not possible for technical reasons, we may also disclose personal data to the following recipient categories, who act as processors:
- development partners,
- professional associations,
We will be happy to provide you with further information on the data recipients involved in specific test drives. Feel free to contact us by e-mail (see paragraph “Contacting us”).
Is data transferred to third countries?
Insofar as recipients are located in a country outside the European Union or outside the European Economic Area (so-called “third-party countries”), the data may be communicated to a country in which there is possibly no appropriate level of data protection, i.e. one that is not comparable with the level in the EU.
Please note that not all third-party countries have a level of data protection considered adequate by the European Commission. For data transfers to third-party countries where there is not an adequate level of data protection, we have taken appropriate steps, e.g. put standard contractual clauses in place to protect personal data. You may request to receive a copy of these steps. For that, please use one of the contact means listed below (see paragraph “Contacting us”).
As data subject, you have the right of access, right to rectification, right to erasure (right to be forgotten), right to restriction of processing, right to data portability and the right to object to processing of personal data concerning you which is based on Art. 6 (1) 1 e) or f) GDPR.
Regarding the right to object the following applies: You have the right to object to the processing of your data at any time for reasons that arise from your particular situation, as long as data processing is based on our legitimate interests or those of a third party. In this case, we will cease to process your data. This does not apply if we can show that there are compelling legitimate grounds for processing that outweigh your interests, or if we need your data for the establishment, exercise or defense of legal claims.
Please note that your above-mentioned rights are restricted by law and must be fulfilled by us possibly only under certain conditions.
Indeed, 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. For instance, we may not be able to retrieve videos of recorded persons without additional information. Since the persons recorded (such as pedestrian, cyclist, motor rider, etc.) cannot be identified without additional information, and since such identification is not necessary for the purposes pursued by us, we are prevented by law from carrying out additional data processing for the purpose of identification; in such case, your rights under Art.15 to 20 GDPR may not be applicable.
Your rights may only apply if you provide us with additional information that enables us to clearly identify you, such as the exact location of the event, the timeframe and your headshot. Even with these additional information we may not be able to verify your entitlement to access or delete the data, since we do not identify any persons on the videos recorded, 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.
If you want to claim your above-mentioned rights, send us an e-mail (see below at section “Contacting us”).
You also have the right to lodge a complaint with a supervisory authority according to Art.77 GDPR. .
The relevant supervisory authority of the data controller is the Italian Data Protection Authority (“Garante”). You can contact Garante via their website: http://www.garanteprivacy.it/web/guest/home_en
FCA Italy S.p.A., Corso Agnelli 200, Torino, Italy.
For a request concerning your above personal rights, please fill the following pdf form and send us by e-mail to firstname.lastname@example.org
For any other requests, please send us an e-mail at email@example.com .
Contacting our Data Protection Officer
FCA Italy S.p.A., with registered office in Corso Giovanni Agnelli 200 – 10135 Turin, Italy. You can contact the Data Protection team at the email address firstname.lastname@example.org