Privacy Notice — Test Vehicle Camera Recording

1. Why you are reading this

You may have passed one of our test vehicles on a public road, or scanned the code displayed on it. Our test vehicles carry forward-facing cameras that record the road ahead. People and vehicles nearby are captured incidentally in the process.

This page explains what is recorded, why, what happens to the material afterwards, and what rights you have.

2. Who is responsible

You may address any request to the controller, to the representative, or to the data protection officer. Whichever you choose, your request will be handled.

3. Where and when

4. What is recorded

• Video from forward-facing cameras covering the road ahead and the adjacent roadway
• Vehicle and sensor data from our own vehicle — speed, steering angle, distance measurements and comparable technical parameters
• Position and time data for the test vehicle

People and vehicles within the camera's field of view are recorded incidentally. Before storage this may include faces and vehicle registration plates.

No audio is recorded.

The cameras are aimed at the road scene, not at any person. We do not identify, name, track or search for individuals.

5. Who is affected

Road users near a test vehicle: pedestrians, cyclists, other drivers and their passengers, and people on footpaths or premises visible from the road.

6. Why we record

We develop and validate driver assistance and automated driving functions. The recordings are used to:

• develop and test how these systems perceive and respond to real traffic
• verify behaviour that cannot be reproduced on a test track or in simulation
• document system performance as evidence for type approval
• investigate any incident involving a test vehicle

7. Legal basis

Article 6(1)(f) GDPR — our legitimate interests in developing and validating these systems, and the public interest in their safety.

We have carried out and documented an assessment weighing those interests against the interests and fundamental rights of the people recorded. The safeguards in section 8 are central to that assessment. A summary is available on request.

8. What protects you

Anonymisation on the vehicle. Faces and vehicle registration plates are automatically detected and irreversibly obscured by software running on the vehicle itself, before the recording is stored for any further use. Only anonymised material leaves the vehicle.

Independent verification. The effectiveness of the anonymisation is sample-checked after the material is received. If recognisable personal data is found, the affected material is quarantined immediately, onward transfer is stopped, and the material is either deleted or handled under separate safeguards.

No linkage. The material is not combined with any other data source and is not used to identify anyone.

No recognition technology. No facial recognition, no identification of registration plates, no behavioural analysis of individuals.

Limited recording. Cameras operate only during active test drives on planned routes.

9. Who receives the material

• Technical service providers operating the storage and transfer infrastructure within the European Union (Frankfurt region), acting as processors under Art. 28 GDPR: processor entities — to be reconciled between MST-2026-07-TUCHENG-001 and the DPO record
• Our own development teams
• Approval authorities, technical services and courts, where required by law or in connection with an incident
• Insurers and legal advisers, in connection with an incident

The material is not passed to anyone else.

10. Transfer outside the EU

The controller is established in the People's Republic of China, and anonymised material is transferred there for development work.

Material is anonymised on the vehicle before it is transferred, so what leaves the European Union is not intended to contain personal data. Should personal data nevertheless be identified in transferred material, the transfer is stopped and the material is handled under the European Commission's Standard Contractual Clauses (Implementing Decision (EU) 2021/914) together with a documented transfer impact assessment. A copy of those safeguards may be requested at the contacts in section 2.

11. How long material is kept

12. Your rights

You have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18) and data portability (Art. 20 GDPR).

There is a practical limit worth explaining. Because faces and registration plates are obscured on the vehicle before storage, the stored material ordinarily does not allow us to identify anyone, and we cannot search it by person. If you tell us the date, time and place of your encounter with a test vehicle, together with anything that would help locate the sequence, we will make reasonable efforts to find it and will respond to you either way. Where we are genuinely unable to identify you from the material, Art. 11(2) GDPR may limit which of these rights can be exercised.

Because retention periods are short, please contact us promptly.

13. Right to object

You have the right to object at any time, on grounds relating to your particular situation, to processing of your personal data based on Art. 6(1)(f) GDPR (Art. 21(1) GDPR).

If you object, we will stop processing the material concerned unless we can demonstrate compelling legitimate grounds overriding your interests, rights and freedoms, or unless the processing serves the establishment, exercise or defence of legal claims.

To object, use any of the contacts in section 2.

14. Right to complain

You may lodge a complaint with a supervisory authority, in particular in the Member State where you live or work, or where the recording took place.

• Germany — the data protection authority of the relevant federal state. name the authorities for the Länder actually driven in
• France — Commission Nationale de l'Informatique et des Libertés (CNIL), 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07
• Spain — Agencia Española de Protección de Datos (AEPD), C/ Jorge Juan 6, 28001 Madrid
• Hungary — Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH), Falk Miksa utca 9–11, 1055 Budapest

Because the controller has no establishment in the European Union, each of these authorities is independently competent; the one-stop-shop mechanism does not apply.

15. Automated decision-making

There is no automated decision-making or profiling producing legal or similarly significant effects concerning you. The systems under test make driving decisions about the vehicle, not decisions about people.

16. Language versions

This notice is available in English, German, French, Spanish and Hungarian. All versions are equally authoritative; if you find a discrepancy, please tell us at the contacts in section 2.

17. Changes to this notice