1. Introduction
Toyota respects your privacy. Whether you deal with Toyota as a customer, a consumer, a member of the general public, etc., you are entitled to the protection of your Personal Data.
In order to develop new vehicle safety functionalities that contribute to safer mobility, we are constantly working to further advance driver assistance and other automated safety systems on our vehicles. This requires extensive research into everyday traffic environment in general, using video footage and images captured on public streets. To this end, we drive our test vehicles equipped with sensors and cameras.
Even though we do not identify any individuals in the collected video footage and images, we would like to ensure transparency of our Test Vehicles Public Data Collection project.
Please read this Privacy Notice together with the General Toyota Privacy and Data Protection Policy (the “General Privacy Policy”).
2. Who is responsible for the collection and processing of collected data?
The entity responsible for the collection and processing of your Personal Data is:
Toyota Motor Europe SA/NV
Avenue du Bourget / Bourgetlaan 60, 1140 Brussels, Belgium
3. What kind of personal data is collected?
The sensors and cameras located inside and outside of the test vehicles take real-time video footage and images of public roads. This footage may include Personal Data, such as:
• Vehicle Licence Plates
• Footage of road users (vehicle, pedestrian, cyclist, motor rider, car driver, etc.) and buildings that are visible from the street
• GPS location of the Toyota test vehicle at the moment where the footage is being recorded
However, we do not use this data to identify and track individuals.
Nor do we have tools allowing such data processing.
4. What can we possibly use your personal data for?
We process your Personal Data if this is necessary to pursue our legitimate interests in relation to the research and development activities in the field of automated driving and automotive safety, provided that our interests are not outbalanced by your interests or rights and freedoms such as privacy rights.
The aim of our data processing is specifically to evaluate new advanced driver assistance systems in the context of real life driving on open roads for the ultimate goal to develop vehicle safety systems that are robust, reliable and efficient, whilst contributing to reducing passenger cars’ environmental footprint.
5. How long do we keep your personal data?
We keep your Personal Data for the following specific periods of time, which are no longer than strictly necessary for the purposes for which they are processed.
• 10 years for conducting research and development projects to further advance driver assistance and other automated safety systems
• Another 5 years if such projects lead to a decision to launch new products or services, and if we need the data to develop such new products or services
• We may keep the data for an extended period from the release of the new product or services if the data is necessary for:
o Improving road safety by developing driver assistance and other automated safety systems, such as vehicle and pedestrian detection systems for collision warning and prevention;
o Legal purposes, such as product liability, litigation;
o Compliance with transparency norms for explainable Artificial Intelligence systems and for ensuring the traceability of those systems and their decision making.
6. Who will receive your personal data?
We may share your personal data with our trusted partners.
They are:
• Toyota Group companies such as Toyota Motor Corporation, Woven Planet Group
• Universities in Europe with whom we partner for some of our research and development projects
• External IT service providers (example: collected footage may be stored on third parties’ cloud infrastructure)
• External research, technology and/or consultancy service providers (example: automatic anonymisation by blurring faces and licence plates)
7. Do we possibly transfer your personal data to countries outside european economic area (“eea”)?
Toyota operates globally. Therefore, your Personal Data may be stored and processed not only by Toyota Motor Europe or our service providers in the country where you live, but also by Toyota entities and service providers in the countries outside of the EEA such as the United Kingdom, Japan, the United States and so on.
If we transfer your Personal Data to any of the countries outside of the EEA, we will make sure to take appropriate safeguards as follows.
• The transfer falls within the scope of an adequacy decision taken by the European Commission under Article 45 of the GDPR; or
• Standard data protection contractual clauses, as approved by the European Commission or a data protection authority pursuant to Article 46.2(c) or (d) of the GDPR, have been established.
We also implement appropriate supplementary measures wherever needed in order to guarantee a level of data protection that is essentially equivalent to the level of data protection in Europe.
You want to know more about how our safeguards are put in place?
Please contact our Data Protection Contact Point (see “11. Who can you contact in case you have questions or requests?” further below)
You want to know more about regulations for personal data transfer to outside of the EEA? Please visit https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/rules-international-data-transfers_en
8. Your rights as data subject
You have the following rights regarding the Personal Data that we hold about you.
• The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Data and your rights related thereto. This is in part why we are providing you with the information in this Privacy Notice.
• The right of access: You have the right to obtain access to your Personal Data. You may wish to access your Personal Data to confirm our use in accordance with applicable data protection laws.
• The right to rectification: You are entitled to have your Personal Data rectified if they are inaccurate or incomplete.
• The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Data where there is no compelling reason for us to keep using it. Please note that this is not an absolute right and exceptions apply.
• The right to restrict processing: You have rights to block or prevent further use of your Personal Data. When processing is restricted, we can still store your Personal Data, but our use of your Personal Data will be restricted.
• The right to data portability: You have the right to obtain and reuse your Personal Data for your own purposes across different services. Please note that this is not an absolute right and exceptions apply. Also, this right can be applied only in certain circumstances and provided it does not adversely affect others’ rights (for example, it can be applied with regard to the Personal Data you provided to us, which we processed in order to fulfil our contract with you).
• The right to object to processing: Where the processing is based on our legitimate interest, you have the right to object to such processing unless we have a compelling and legitimate reason to continue processing your Personal Data.
• The right to lodge a complaint: You have the right to lodge a complaint about the way we handle or process your Personal Data with your national data protection authority.
• The right not to be subject to automated-decision making: You have the right not to be subject to a decision that is based solely on automated processing (including profiling) and that produces legal effects for you or similarly significantly affects you.
9. Changes to this privacy notice
Toyota may update this Privacy Notice. When we do so, we will publish a revised Privacy Notice on the TME website.
Questions about any changes to this Privacy Notice?
Please contact our Data Protection Contact Point (see “11.Who can you contact in case you have questions or requests?” further below)
10. Conflicts or inconsitencies between this privacy notice and general Toyota privacy and data protection policy
Toyota may update this Privacy Notice. When we do so, we will publish a revised Privacy Notice on the TME website.
Questions about any changes to this Privacy Notice?
Please contact our Data Protection Contact Point (see “11. Who can you contact in case you have questions or requests?” further below)
11. Who can you contact in case you have questions or requests?
For any questions and complaints about our Test Vehicles Public Data Collection project, or request to exercise your rights to Personal Data, please contact our
Data Protection Contact Point:
Data.Protection@toyota-europe.com
Toyota Motor Europe NV/SA
Attention : TME Data Protection Contact Point
Avenue du Bourget / Bourgetlaan 60, 1140 Brussels, Belgium