Aptiv Driver/Cabin Monitoring System Test Drive - Privacy Notice
Recording Privacy Policy

Aptiv Driver/Cabin Monitoring System Test Drive - Privacy Notice

Scope and Overview

As a Data Controller, Aptiv Services Poland S.A. (located D-E, Powstańców Wielkopolskich 13, 30-707 Kraków, Poland) and its group companies (together “Aptiv”) is committed to protecting your Personal Data. At Aptiv, we are committed to building smarter, safer, and more inclusive automotive products that work for everyone - regardless of race, ethnicity, or gender. Your contribution helps us ensure that our products reflect the diversity of all drivers globally, improving vehicle safety, connectivity, and enhancing the overall driving experience.

This Privacy Notice describes how we collect and process your Personal Data during the testing, validation and development of our Driver Monitoring System "DMS" or Cabin Monitoring System "CMS".

Personal Data We Process

Depending on Product/Technology requirements, the types of Personal Data we collect, and process may include the following:

  • Full name,
  • Personal/Work Email Address,
  • Signature,
  • Audio or Video Recording,
  • Facial and Retinal Biometrics,
  • Other Facial Features (beard size, moustache, tattoos, piercings),
  • Eye Features and Properties (colour, size, contact lenses, glasses, eyelashes etc),
  • Eye‑related medical history
  • Head Features (headgear, hair length),
  • Racial or Ethnic Origin,
  • Nationality,
  • Skin Tone,
  • Gender,
  • Height,
  • Exact Weight,
  • Body Measurements, hip to head, shoulder width, upper arm length, arm span etc), and
  • Age.

Purposes of Collecting Your Data

The purposes of collecting your Personal Data are to enable us to test, validate and further develop our DMS/CMS to ensure that the products are universal and inclusive, and to evidence our compliance with applicable regulatory requirements.

How We Obtain Your Data

We obtain your Personal Data directly from you when:

  • you complete our relevant compliance documentation (consent forms etc), and
  • we collect it during our DMS/CMS test drives (through our in-cabin data collection using interior sensors and cameras etc.).

Our Lawful Basis of Processing

We rely on your explicit consent as the lawful basis for processing your Personal Data.

Data Sharing and Transfer

As part of this Technology/Product Development, Aptiv may share your Personal Data with our trusted automotive partner(s) and service provider(s) in Europe (including countries recognized by the EU Commission to provide adequate protection). We may also require transferring your Personal Data across International borders, in line with applicable law. To ensure that International Transfers of Personal Data are adequately protected, and your rights are preserved, we have put in place appropriate contractual, technical and organizational measures, and conducted Transfer Impact Assessments and Data Protection Impact Assessments as required.

Data Retention

We will retain your Personal Data only for as long as necessary to fulfil the above purposes, or as required by applicable law.

Data Subjects’ Rights

In accordance with applicable law, in certain circumstances, you have the follow-ing rights regarding the processing of your Personal Data:

  • The right to be informed about the processing of your data.
  • The right to access your data.
  • The right to correct or rectify your data.
  • The right to have your data deleted or erased.
  • The right to restrict the processing of your data.
  • The right to not have your personal data processed if the purpose of processing your personal data changed, without your express consent.
  • The right to withdraw consent at any time.
  • The right to make any complaints arising from to the competent authority.

If you wish to exercise your rights, or have further questions, please contact Aptiv’s Privacy Office at privacy@aptiv.com quoting ‘DRIVE T2’. The Aptiv Privacy Office is located in Dublin, Ireland (Aptiv Global Operations Limited, 5 Hanover Quay, Grand Canal Dock, Dublin, Ireland).

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

We may need to request specific information from you to help us confirm your iden-tity 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 Data is not disclosed to any person who has no right to receive it.

Complaint Procedure

Depending on your jurisdiction, you also have a right to make a complaint at any time to your local Data Protection Supervisory Authority listed here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Alternatively, Aptiv Global Operations Limited is an Irish Company, and it’s lead EU Regulator is the Irish Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD 28, Ireland or you can e-mail them at info@dataprotection.ie.