Data protection information for test vehicles

To test automated and connected driving functions and to develop new testing technologies, we use marked test vehicles in demarcated operating areas on public roads. We provide information below about how we handle personal data that may be collected in connection with test drives of our vehicles.

1. Controller

The controller responsible for the collection and processing of your personal data is:

FSD Fahrzeugsystemdaten GmbH

Central Agency under the German Road Traffic Act (StVG)

Wintergartenstraße 4
01307 Dresden
Germany

You can contact the controller at: datenschutz@fsd-web.de

2. Contact details for the data protection officer

Our data protection officer is available to answer your questions and act as a contact person for data protection issues. Their contact details are:

FSD Fahrzeugsystemdaten GmbH

Central Agency under the German Road Traffic Act (StVG)

Wintergartenstrasse 4
01307 Dresden
Germany

You can contact our data protection officer at dsb@fsd-web.de or on +49 (0)351 / 652888176

3. Categories of personal data

The test vehicles are equipped with various sensors and camera systems, which capture and process video data from the vehicle’s immediate surroundings.

Depending on the individual situation, this data may contain the following personal information:

  • Images of road users such as pedestrians and cyclists;
  • Number plates of other vehicles;
  • Other information in the immediate vicinity of the test vehicles that is captured by cameras.

4. Purposes of processing and legal basis

Data processing is carried out for research and testing purposes, for the further development of testing technologies in the areas of automated and connected driving, and for the safe operation of the test vehicles. The legal basis for processing is the legitimate interest in conducting research, development and testing of automated and networked driving functions and systems in order to improve road safety (point (f) of Article 6(1) GDPR).

5. Categories of recipient

We do not forward personal data to third parties.

6. Storage periods

The data will only be stored for as long as is necessary for the research and testing purposes set out above.

7. Your rights

As a data subject, you have the following rights if the legal requirements are met. Please also note the specific information regarding the exercise and restriction of these rights in relation to the processing described here.

Special information on exercising the rights of the data subject:

The real images of public road traffic captured by the cameras of the test vehicles are only processed for the purpose of recording the vehicle’s surroundings. The detection of obstacles and other road users serves to ensure the safe operation of the test vehicles and to prevent collisions. Apart from the recorded video and image data, no additional identifying features of the persons concerned are normally processed. It is therefore fundamentally impossible for us to identify individual persons and vehicles, nor is this intended.

In this respect, this constitutes “processing which does not require the identification of a data subject”, Article 11 GDPR. The exercise and enforcement of a data subject’s rights will therefore often require additional information from the data subject, depending on the individual case. We will inform you if we are unable to identify you. You will then have the opportunity to provide further information. This applies in particular to information about the location and time at which you were in the vicinity of a test vehicle and could be affected by the processing.

Right of access:

You can obtain information as to whether or not we process your personal data. If this is the case, you have the right to obtain information about these personal data and other information related to their processing.

Right to rectification:

You have the right to obtain from the controller the rectification and/or completion of the processed personal data concerning you if they are inaccurate or incomplete.

Right to restriction of processing:

Unter den Voraussetzungen des Art. 18 DSGVO haben Sie das Recht, die Einschränkung der Verarbeitung der Sie betreffenden personenbezogenen Daten zu verlangen.

You have the right to be informed of these recipients by the controller.

Right to erasure:

You have the right to obtain the erasure of your data if the conditions set out in Article 17 GDPR are met.

According to the second sentence of Article 20(3) GDPR, you do not have this right if the data processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Right to data portability:

If the data processing is based on consent or the performance of a contract and is also carried out by automated means, you have the right to receive your data in a structured, commonly used and machine-readable format and to transmit those data to another data processor.

Right of withdrawal:

If the data processing is based on consent, you have the right under Article 7(3) GDPR to withdraw your consent to data processing free of charge at any time with effect for the future.

Right to lodge a complaint:

If you believe that our processing of the personal data concerning you is unlawful or that we are infringing data protection law for other reasons, you can lodge a complaint with the supervisory authority. The address of the supervisory authority responsible for us is: Saxon Data Protection and Transparency Commissioner,
postal address: P.O. Box 11 01 32, 01330 Dresden, visitor address: Materniestraße 17, 01067 Dresden,
email: post@sdtb.sachsen.de

Right to object:

Under Article 21 GDPR, you have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you if the processing is based on points (e) or (f) of Article 6(1) GDPR. This is particularly the case if the processing is not necessary for the performance of a contract with you. When exercising such an objection, unless the objection is to direct marketing, we ask that you explain the reasons why we should not process your data as we have done. If your objection is justified, we will examine the situation and either cease or adjust the data processing or set out our compelling legitimate grounds on the basis of which we will continue the processing. You can send your objection by email to datenschutz@fsd-web.de.

Last updated: 28 August 2023