MAN Truck & Bus

INFORMATION ON DATA PROTECTION DURING TEST DRIVES

Last updated: June 2024

1. GENERAL INFORMATION

A) INTRODUCTION

The protection of your personal rights when processing personal data is an important concern for MAN Truck & Bus SE. We process personal data (hereinafter also referred to as "data") in accordance with the applicable data protection regulations. Our employees are obliged to maintain confidentiality with regard to the handling of personal data.

All vehicles used by MAN Truck & Bus SE for the purpose communicated inhere are approved for use on public roads. Stickers with the essential information requirements and notices, such as the use of cameras, are attached to all sides of the vehicle and to trailers used.

B) CONTROLLER AND CONTACT

The controller within the meaning of data protection law is MAN Truck & Bus SE, Dachauer Str. 667, 80995 Munich, Germany.

IF YOU HAVE ANY PRIVACY-RELATED QUESTIONS, PLEASE USE OUR ONLINE CONTACT FORMAT THE FOLLOWING LINK:

Contact

2. COLLECTION AND PROCESSING OF PERSONAL DATA

A) PURPOSE

For the (further) development and testing of driver assistance and driver information systems as well as automated driving functions (e.g. for active and passive safety) and for comfort functions, our test vehicles use various sensors and video cameras in the vehicle to record environmental data, images and audio. The cameras enable 360° recording around the vehicle, with a maximum range of 500 metres. The audio recording is only used to record typical road traffic noises. The recorded environmental data is stored in a secure database and used exclusively for the (further) development and validation of driver assistance and driver information systems, automated driving functions and comfort functions, as well as the necessary tests. These systems are intended to improve comfort and safety in road traffic and to ensure the functionality of the vehicle for participation in road traffic through the recorded video data. Processing the existing traffic infrastructure and recognising road users, including their direction of movement, is necessary in order to derive the correct vehicle response. In this context, static and dynamic traffic objects are recorded (e.g. road markings, cars, motorbikes, bicycles, pedestrians, etc.) and possible movements of road users are calculated.

MAN Truck & Bus SE does not aim to identify individuals and our systems are not designed to fulfil such tasks, as this is not necessary for the development of the platform for assisted, connected, partially automated and autonomous driving.

AI applications are also used to achieve the above-mentioned purposes.

B) LEGAL BASIS(S) FOR THE PROCESSING OF THE DATA BY MAN TRUCK & BUS SE

The collection, processing and use of your personal data is based on a balancing of interests in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR. MAN Truck & Bus SE has a legitimate interest in processing your data for the (further) development and testing of driver assistance and driver information systems as well as automated driving functions and comfort functions. In addition, quality assurance measures (necessary testing for safeguarding) are to be carried out, product, vehicle and road safety are to be improved, and thus traffic accidents are to be reduced.

C) THE PROCESSED DATA ARE CLASSIFIED UNDER THE FOLLOWING CATEGORIES OF DATA:

Video/image and audio recordings of:

  • road users (vehicles and people),
  • license plates (license plates) and lettering on vehicles,
  • lettering on shops and street signs, and
  • other information in the immediate vicinity of the test vehicles, which is recorded by sensors.

3. DISCLOSURE OF PERSONAL DATA

Within MAN Truck & Bus SE, the data is received by those departments that require it in the course of their work (e.g. product development in technical development).

In the (further) development of driver assistance and driver information systems as well as automated driving functions and comfort functions, MAN Truck & Bus SE cooperates with service providers who process the data in compliance with the applicable data protection law on the basis of corresponding order processing agreements within the meaning of Art. 28 GDPR:

  • Development service providers,
  • Suppliers of safety-related driver assistance system components,
  • Hosting service providers,
  • IT service providers.

MAN Truck & Bus SE is working with cooperation partners on the (further) development of driver assistance and driver information systems as well as automated driving functions and comfort functions. These companies are involved in product development and the evaluation of tests and receive the data as data protection controllers:

  • Companies of the TRATON Group,
  • development partners and
  • Universities

MAN Truck & Bus SE will provide you with further information on the recipients for specific test drives, upon your request. Due to the separate data protection responsibility of our cooperation partners, they are responsible for exercising your rights as data subjects. We will be happy to give you the name of our current cooperation partner for the purpose of the data processing mentioned and provide you with the necessary contact details. Please use the online contact form.

If recipients are located in a country outside the European Union or the European Economic Area (so-called third country), the data may be transferred to a country in which there may not be an adequate level of data protection, i.e. no level comparable to that in the EU.

Please note that not all third countries have a level of data protection recognized as adequate by the European Commission. For data transfers to third countries where there is no adequate level of data protection, MAN Truck & Bus SE has taken appropriate measures, such as the conclusion of so-called standard contractual clauses, to protect your personal data.

Cooperation with Scania CV AB

In particular, there is a joint cooperation with Scania CV AB in the field of the development of autonomous systems (including joint collection and analysis of the listed data), in which both companies act as joint controllers within the meaning of Art. 26 GDPR.

IF YOU HAVE ANY PRIVACY-RELATED QUESTIONS TO SCANIA CV AB, PLEASE USE THE ONLINE CONTACT FORM AT THE FOLLOWING LINK:

https://www.scania.com/group/en/home/admin/misc/privacy-statement/contact-privacy.html

For more information on data protection at Scania CV AB, please visit:

https://www.scania.com/group/en/home/admin/misc/privacy-statement/data-we-process.html

4. DATA STORAGE AND DELETION

The data will only be stored for as long as is necessary for testing and trial purposes as well as quality assurance measures, including long-term observations, and development purposes. The further development of the systems also includes a possible quality improvement and troubleshooting after market launch. In certain cases, MAN Truck & Bus SE is legally obliged to carry out this troubleshooting for product liability reasons.

5. YOUR RIGHTS

In addition to the right to request information about the data concerning you and the correction of your data, you also have the right to erasure and a right to object to the processing or the right to restrict the processing of your data, insofar as there are no legal regulations to the contrary. You also have the right to data portability.

As the persons recorded within the vicinity of the test vehicle cannot be identified without additional information, we require additional information - in the event of the exercise of data subject rights - with which we could clearly identify you in order to determine whether you are a data subject and to protect your rights, taking into account the rights of third parties. This would be photos of your person or your vehicle and the licence plate number, as well as precise information about the place, day and time at which you may have been recorded.

If we collect and process your personal data on the basis of your consent, you also have the right to withdraw the consent you have given with effect for the future. Your revocation does not affect the lawfulness of the data processing carried out on the basis of the consent before the revocation. Where necessary, we will need to verify your identity before we can process your requests.

If, despite our efforts to ensure that the data is correct and up-to-date, incorrect or incorrect information is stored, we will correct it as soon as possible after being informed or becoming aware of this. In the event of complaints, it is possible to contact a data protection supervisory authority.

IF YOU HAVE ANY QUESTIONS REGARDING DATA PROTECTION, PLEASE USE OUR ONLINE CONTACT FORM AT THE FOLLOWING LINK

Contact

6. SECURITY

Your data will be protected by MAN Truck & Bus SE by means of appropriate technical and organizational security measures to prevent accidental or intentional manipulation, alteration, loss, destruction or access by unauthorized persons or unauthorized disclosure.

Our security measures, such as data encryption, are regularly monitored and improved in line with technological developments.