Identity, Contact Details and Representative of Controller
The controller is Mobileye Vision Technologies Ltd. of Hartom 13, Jerusalem, 9777513, Israel, email: firstname.lastname@example.org. The controller’s representative within the EEA is its affiliate Mobileye Germany GmbH of Lütticher Str. 132, 40547 Düsseldorf, Germany
Collection of Road Clips
Certain test-vehicles operated by Mobileye itself or by Mobileye customers are fitted with prototype products which, as those vehicles are driven along the public road, collect and store a video-recording of the outside of the vehicle in the form of a series of clips ('Clips'). Occasionally, these Clips also capture sound. Naturally, Clips may contain personal information ('PI', which is information relating to an identified or identifiable natural person). The PI in this case principally comprises: (i) facial images, and (ii) vehicle license-plates. (It should be noted that although Clips may contain 'special categories of personal data', the collection of such data is incidental, and Mobileye certainly does not perform any processing or any other analysis on or in relation to them.)
In the case of customer-operated test-vehicles, Clips are conveyed to Mobileye via secure file transfer or upon physical disks. (Mobileye customers may also retain copies of such Clips for their own internal purposes.)
What does Mobileye do with Clips? (the 'purpose of processing')
Mobileye uses Clips for internal product development, validation, testing and research purposes in the fields of advanced driver assistance systems and autonomous vehicles. In particular, we use them to 'train' and test our technology; principally, to improve its accuracy at identifying what one might expect to see on the road, e.g. other vehicles, pedestrians and street furniture. But, to the extent that Clips contain PI, Mobileye is interested in it only in its generic form (that is, the generic shape or appearance of a face or a license-plate, not the details of a particular face or license-plate), so that, for example, Mobileyes technology can become even better at identifying pedestrians and distinguishing them from other sights.
What is Mobileyes legal basis for collection and use of Clips? (the 'legal basis for the processing')
Mobileye has a legitimate interest (in the understanding of Article 6(1)(f) of the EU General Data Protection Regulation – below, the 'GDPR') in collecting and using the Clips for the above purpose – which is to improve Mobileyes technology powering advanced driver assistance and autonomous driving solutions and due, eventually, to power autonomous vehicles – all of which is expected to lead to the indisputable social benefit of vastly reduced road casualties and fatalities (and which has already saved lives).
Storage of Clips within Mobileye
Mobileye utilises state-of-the-art technology to store Clips, for example:
a) Access to them is restricted only to authorised persons for the stated purposes;
b) Where stored locally on Mobileyes own servers, they are in a proprietary encoded format, such that only Mobileye can play them back; and where stored in the Mobileye cloud (hosted by AWS), they are stored in an encrypted form; and
c) Access to these IT systems is monitored to detect and prevent misuse.
Transfer of Clips outside of Mobileye ('categories of recipients of personal information')
Clips 'leave' Mobileye in only a few, specific scenarios:
a) Where Clips are stored with third parties such as AWS, leveraging such parties massive computing power and real-time scalability; or
b) Where Mobileye shares a certain number of them, in compressed form, with off-site employees in Israel or with external contractors worldwide, for the purpose of tagging, i.e. the contractors employees either (i) 'tag' certain features of a clip in order to train and refine software identification accuracy; or (ii) perform after-the-fact review of the accuracy of computerized 'tagging'; or
c) Where Mobileye shares a very small number of individual Clips or (data derived from them) with third-party customers or partners for business-related purposes; or
d) Where, in order to demonstrate how Mobileye technology works, Clips are featured on Mobileyes various websites or social media channels, or senior Mobileye representatives play them before an audience of customers or potential customers, or at a corporate or trade event. In any event, the number of Clips involved is minimal and any PI within them is blurred where and to the extent practicable.
Transfer of Clips under sub-sections a)-c) is done either (i) through upload to and download from secure private services (and not, for example, through third-party web-based services) or (ii) on physical media with reputable international couriers (the physical media itself is secured through encryption or other technical means).
In the case of transfer of Clips to third countries, Mobileye relies on a combination of European Commission adequacy decisions, standard data protection clauses and appropriate technical and organizational measures.
Clip Retention Duration
Mobileye retains the Clips for as long as they continue to be useful for the purposes stated above, or in accordance with applicable laws, whichever is shorter.
Individuals Rights in respect of their PI contained within a Clip or Clips
Individuals have various rights under the GDPR in respect of PI pertaining to them. However, please note that these rights are necessarily limited due to the fact that Mobileye neither collates nor indexes PI (there is no mechanism allowing, for example, a search through the Clips database for a frame or frames containing any particular vehicle or individual). As a result, it is highly unlikely that Mobileye would be able to identify a particular individual within its Clips database unless that individual could provide additional information, such as the location and time at which he/she believes the relevant Clip or Clips were collected.
Nonetheless, Mobileye will review and respond to any requests on a case-by-case basis. In the unusual case where an individual registers an objection with the driver of a Mobileye-operated test-vehicle in real or close-to-real time, drivers are instructed to make a record of such objections and to relay them for review. In such exceptional case, by contrast to the above, it would usually be possible to identify and delete the relevant Clip or Clips.
Individuals Right to Lodge a Complaint
An individual may lodge a complaint with their local supervisory authority. A list of supervisory authorities (correct at the time of publication of this Notice) may be found here.
Mobileye Clip-collecting test vehicles are marked with a sticker showing their provenance:
(The above sticker is an example.)
For more information about how we may collect and use your personal information via our websites, products, services and technologies please see our General Privacy Notice
How to Contact Us
If you have questions or concerns about Mobileye’s privacy practices, or to exercise any of your rights and choices as described in this Notice, you can contact us using any of the following methods. Please include your contact details and a detailed description of your request or privacy concern:
- By email to the Data Protection officer at email@example.com;
- By mail to the address below:
Mobileye Vision Technologies Ltd
Attn: Privacy/Legal Department
13 Hartom St. Har Hotzvim,
Jerusalem, Israel 9777513 In the European Economic Area, by contacting our European Data Protection Officer at the address below:
European Data Protection Officer
Mobileye Germany GmbH
Lütticher Str. 132
40547 Düsseldorf, Germany