Privacy Notice APTIV Test Drive 

Aptiv Holdings (US), LLC (located 5725 Delphi Drive Troy, MI 48098 United States) and its group companies (together “Aptiv”) is developing new Safety Products for Cars.

 In order to do so, Aptiv is recording videos on public roads, for the purpose of developing technology that can detect ‘objects’ on the road. Any recording of persons or personal data is incidental and is therefore not the purpose of recording, however, such incidental recording will be processed under the lawful basis of legitimate interest.

 As part of the technology development, Aptiv will share recordings with our trusted Safety Product Development partner and service provider in Europe (including countries recognized by the EU Commission to provide adequate protection) and USA by entering into contractual agreement based on EU commission’s standard contractual clauses. In case of transfer, we will take appropriate measures to ensure your personal data remains protected to the standards described in this privacy notice. Since Aptiv is developing Car Safety Products, we are obliged to adhere to Product Safety Development retention periods.

Please note: Where you have seen the car driving in public, the camera(s) may or may not have been recording. In the event that the camera(s) were recording, the recording angle is limited and therefore may not have captured recordings of any personal data.

The Scope of this Privacy Notice
This Privacy Notice covers Test Drives in different countries. In order to afford equivalent Data Protection standards to all Data Subjects for the processing activities involved in these Test Drives, and notwithstanding imbalances between the GDPR and different Data Protection law, Aptiv abides by the principles and standards of the GDPR, even when not required.

Your Rights
In certain circumstances, and under applicable law, you have the following rights: 

Right of access:
You can request information at any time as to how and which personal data concerning you will be used by us, for what purposes the data will be processed, where the data originated from, to which recipients the data may be transferred and how long such data will be stored by us.

Right of rectification:
If you find that personal data concerning you are inaccurate, you may request rectification of such data at any time. If, in your opinion, the data is incomplete, you may also request that it be supplemented.

Right to deletion: 
If you are of the opinion that the use of your personal data is no longer necessary or takes place without sufficient legal basis or is unlawful for other reasons, you can request the deletion of this data. 

Right to limit the use of data:
Instead of deleting data, you can also request a restriction on the use of data if it is used improperly.

Right of objection: 
If particular circumstances give you reasons which make the use of your personal data inadmissible, you can object to such use of data. 

Rights to complain to a regulatory authority: 
If you believe that your rights in relation to personal data concerning you have been violated, you have the right to submit a complaint to the Data Protection Commision in Ireland also you may file a complaint towards the competent regulatory authority as defined in Article 77 (GDPR).

Exercising your Rights
If you wish to exercise your rights, or have further questions, please contact the Privacy Office at privacy@aptiv.com quoting ‘DRIVEA’. Aptiv’s Privacy Office is located in Dublin, Ireland (Aptiv Global Operations Limited, 5 Hanover Quay, Grand Canal Dock, Dublin, Ireland).

If you wish to exercise your rights, we will ask you for further information regarding the date, place and time wherein the recording may have happened, in order to check if any recording was in operation.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.