Privacy Notice APTIV Test Drive 

Aptiv Services Poland S.A. (located D-E, Powstańców Wielkopolskich 13, 30-707 Kraków, Poland) and its group companies (together “Aptiv”) is developing new Advanced Driver Assist Technology Systems. In order to develop this product, Aptiv is recording videos during Test-Drives on public roads.

This Privacy Notice explains if and how we process Personal Data during Test Drives in different EU countries.

Please note: Although you may see our cars with camera(s) driving on public roads, the camera(s) may, or may not, be recording at that moment. In the event that the camera(s) are recording, please be aware that the angle of video-capture is very limited, and therefore may not have captured recordings of any Persons (and therefore Personal Data) on the road.

During our Test-Drives, the purpose of recording is to develop our Automotive Software, to improve Automotive Safety and interpret road-traffic systems. Any inadvertent recording of Persons (or Personal Data) is incidental, and is not the purpose of recording. Whenever such incidental recording happens, we process this Personal Data under the lawful basis of legitimate interest.

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

Data Subjects’ Rights

In accordance with applicable law, in certain circumstances, you have the following rights with regard to 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 your data if it is incorrect
• The right to have your data erased
• The right to restrict processing of your data
• The right to object to processing, including the right to object to direct marketing
• The right to have a copy of your data transferred to different Third Party

 If you wish to exercise your rights, or have further questions, please contact the Aptiv’s Privacy Office at privacy@aptiv.com quoting ‘DRIVEL’. Aptiv’s 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 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 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.