Road testing and recording privacy notice

SonicRide GmbH · Bockenheimer Landstrasse 17-19 · 60325 Frankfurt am Main · Deutschland
[email protected]

The controller must be identified from the actual decisions about purposes and essential means. SonicRide may act as controller, processor or sub-processor. Manufacturer and customer identities and roles must be established in programme-specific information. Contacting SonicRide helps route requests but does not make it the sole controller of every programme.

Data may come from factory-installed exterior cameras and related sensors expressly configured for a programme. Images may incidentally include road users, faces, plates, location, routes, actual capture dates and times, camera information, technical vehicle data and specified labels or annotations. Fields, views, resolution and recording triggers or start/stop arrangements require programme confirmation.

The data scope is determined for each programme. Current proposed arrangements do not plan audio or in-cabin collection; changes need assessment and updated information before implementation.

Road data may support vehicle development, testing, validation, ADAS and automated-driving analysis. Where AI training, annotation or product use is intended, the programme notice must identify the specific purpose, necessity and boundaries of use.

This general notice does not authorise AI training, expanded use or cross-programme reuse. Actual purposes, necessity and recipient-use boundaries must be documented and assessed. Identifying or tracking ordinary road users is not the purpose of road testing.

Where legitimate interests are proposed, Article 6(1)(f) requires assessment of purpose, necessity, less intrusive alternatives and individual rights, alongside national law. The impracticality of individual consent does not itself make recording lawful; later masking cannot replace an assessment of collection.

The programme DPIA, LIA, Article 14 information assessment and relevant national-law review should address the full lifecycle. Website notices and signage provide transparency; they are not evidence of completed assessments or authorisation.

Accidents, medical assistance, religious or political activities may incidentally involve sensitive information. Articles 9 or 10 require additional conditions where applicable. Scope, field of view, locations, periods and recording methods must be assessed for necessity. Additional restrictions on processing, access and disclosure may be needed.

The proposed workflow includes European collection, processing in Germany and face/plate masking with quality checks before authorised release. Media transport, uploads, permissions, integrity and recovery must be supported by confirmed and validated programme arrangements.

Masking does not necessarily mean irreversible anonymisation. GPS, actual capture times, routes and surroundings may still enable identification. Retention and safeguards for those fields require a necessity-based programme assessment, not a blanket promise of removal or no risk.

Recipients may include authorised SonicRide personnel, engineering or processing providers, cloud infrastructure, authorised clients/manufacturers and legally empowered authorities. The programme notice and access review must confirm actual entities, viewers/downloaders, locations, systems and onward-disclosure conditions. Operating a vehicle does not itself authorise copying footage.

A proposed programme may involve making processed data available in China. Where individuals remain identifiable, the applicable transfer mechanism, transfer-impact assessment and supplementary measures must be established. Masking alone does not establish that Chapter V is inapplicable.

The programme-specific notice identifies the actual regions, cloud environment and locations of recipient copies and access. Contact us about relevant safeguards and obtaining a copy.

Measures may include authorised access, authentication, encryption, media custody, logs, confidentiality, incident response and quality/integrity checks. Vehicle, drive, transport, upload, cloud and recipient-copy controls require separate verification.

Storage, transfers, vehicle media and recipient copies require appropriate safeguards at each stage. The scope is established by programme arrangements and validation.

Retention periods and deletion conditions are set out under the confirmed rules for the relevant programme. An access-expiry date is not the deletion date of each batch. Final periods must be specified in the programme notice.

Subject to law, you may request access, correction, erasure, restriction or portability, or object on grounds relating to your situation to legitimate-interest processing. Email [email protected] with the approximate date, time, location, vehicle description and relevant circumstances. Avoid unnecessary identity documents in the first message.

The normal response period is one month; a legally permitted extension will be explained within that month. Article 11 and other applicable rules apply where identification is not possible using reasonably available information. Location and deletion of every recording cannot be guaranteed. We assist the appropriate controller where acting on its behalf.

You may complain directly to the competent EU/EEA authority where you normally live, work or believe an infringement occurred. See HBDI for SonicRide’s own German processing, or the EDPB authority directory.

Signage should include a readable short URL and QR code, with suitable local-language information. This site offers Chinese, English and German; activities elsewhere may require additional languages. The final notice, controller and signage URL should be confirmed before the relevant activity starts.