Privacy Policy for the Development of ADAS
By means of this privacy policy, we inform you about the processing and use of your personal data by SEAT, S.A.U. for the development and improvement of driver assistance and automated driving functions, as well as additional services that may be appropriate to increase road safety in general.
We inform you that SEAT, S.A.U. is a Spanish manufacturer of approved commercial vehicles operating under the SEAT and CUPRA trademarks. Hereinafter, SETA, S.A.U may be referred to as SEAT or CUPRA indistinctly.
1. Who is the Data Controller?
- SEAT, S.A.U. with NIF A-28049161.
- Address: Autovía A-2, Km. 585, Martorell (Barcelona, Spain)
- Contacto: customercare@cupraofficial.com / customercare@seat.es
2. What type of data do we process and what is its origin?
Our vehicles are equipped with cameras and sensors outside the vehicle, capable of collecting certain data and information from public roads in certain circumstances:
- Recordings of images and videos of other road users (vehicles and people),
- Vehicle registration and labeling,
- Any other type of information in the vicinity of the vehicles, which is recorded by means of external sensors, supported by the GPS position and the timestamp.
3. For what purpose do we process your data and what is the legal basis?
The purpose of data recording and processing is to develop and improve driver assistance and automated driving functions (ADAS functions, necessary for the approval of future vehicles, as well as those services and functions related to the vehicle, which may be suitable to increase general road safety.
Data recording and processing are carried out in predefined and specific traffic situations by means of events or campaigns created for this purpose, through the use of sensors and image acquisition technology.
These "events" or traffic situations can be safety-critical situations, such as emergency braking or local peculiarities, such as poor lane markings, special traffic signs.
The recognition of these critical situations for road safety, as well as the subsequent development and optimization of systems and functions is an important part of the continuous improvement of the driver assistance systems of our vehicles.
This data processing may affect any person who is occasionally in the vicinity of the vehicle or is directly involved in a traffic situation critical to the safety of people. In these cases, our vehicles could collect their image at a certain time.
Notwithstanding the above, we inform you that the possible images and data obtained are anonymized through a pixelation process and in a maximum time of 48 hours. From this point on, people, vehicles or other objects that may be found outside are considered as "anonymous objects" in the context of traffic, such as "pedestrians on the right side of the road". We use the information to improve the software and remove those personal characteristics that are not relevant to the development of the driving and road safety system.
The processing of your personal data is carried out on the basis of our company's legitimate interests in accordance with Article 6(1)(f) GDPR for the purpose of increasing overall road safety. If you would like more information, please contact our Data Protection Officer.
4. How is your data kept and for how long?
Pixelated images will be stored for a maximum period of 1 year for the purposes indicated above, unless it is necessary to store them for longer periods of time for legal reasons.
5. Who are the recipients of your data?
In general, we inform you that we will not communicate your personal data to third parties except to comply with a legal obligation. However, as approved manufacturers of SEAT and CUPRA vehicles, we will be obliged at the request of the competent Authorities to process and communicate certain data stored in the vehicle related to the owner of the vehicle.
Some of these obligations may arise from the investigation of crimes, the occurrence of traffic accidents, the control of second-hand sales, etc. The processing and communication of data to the Authorities is covered by compliance with a legal obligation (Art. 6.1 c) General Data Protection Regulation), as manufacturers.
On the other hand, third parties acting as data processors and sub-processors may also have access to the data in order to be able to offer some functions and services related to the purposes established above. Under no circumstances will these third parties process the data for their own purposes.
Finally, our entity is part of the Volkswagen Group. In this regard, we inform you that we use data servers provided by the Volkswagen Group, which also provides maintenance and technical support to the IT systems of our vehicles. These third parties and Volkswagen's suppliers will always process personal data on our behalf and in accordance with our instructions.
6. Will your data be transferred outside the European Economic Area?
In general, the processing of your data will be carried out within the European Economic Area. However, some of our providers may be domiciled outside the European Economic Area, such as Microsoft Azure or Amazon Web Services, providers of our "cloud" storage infrastructure. These entities adhere to the secure EU-US transfer framework (Data Privacy Framework). More information at this link: https://www.dataprivacyframework.gov
7. What are your rights as a data subject?
Your rights as a data subject are set out below:
Right | Content |
Access | You can obtain confirmation as to whether we process your personal data, as well as consult your personal data included in our files. |
Rectification | You may modify your personal data when they are inaccurate, as well as complete those that are incomplete. |
Suppression | You may request the deletion or deletion of your personal data when, among other reasons, the data is no longer necessary for the purposes for which it was collected. |
Opposition | You may request that your personal data not be processed. Our organisation will no longer process the data, except for compelling legitimate reasons, or the exercise or defence of possible claims. |
Limitation | You may request the limitation of the processing of your data in the following cases: • While the accuracy of your data is being challenged; • When the processing is unlawful, you object to the deletion of your data, and request the limitation of its use; • When we do not need to process your data, but you need it for the exercise or defence of claims; • When you have objected to the processing of your data for the fulfilment of a mission in the public interest or for the satisfaction of a legitimate interest, while it is verified whether the legitimate grounds for the processing override yours. |
Portability | You may receive, in electronic form, the personal data you have provided to us and those obtained from your contractual relationship with us, as well as transmit them to another entity. |
The exercise of these rights is free of charge except in the case of manifestly unfounded or excessive requests. In the event that there is reasonable doubt about your identity, you may be asked for additional information necessary for us to confirm it and thus be able to respond to your right.
8. How can you exercise your rights?
You can exercise these rights by submitting a written request to SEAT, S.A.U. Autovía A-2 Km. 585, Martorell (Barcelona) or to the email address customercare@cupraofficial.com or customercare@seat.es. The exercise of these rights does not entail any cost unless their exercise is unfounded or excessive. In the event that you consider that we have not processed your personal data in accordance with the applicable regulations, you may file a complaint with the Spanish Data Protection Agency (through the website www.aepd.es. or competent supervisory authority.
9. Data Protection Officer
If you have any questions about data protection or wish to contact our Data Protection Officer ("DPO"), you can contact them by emailing them at dataprotection@seat.es.