Test Vehicle Privacy Notice (RESIM)
Ampere SAS, a subsidiary of Renault Group, uses test vehicles to develop, test and validate the ADAS (Advanced Driver Assistance Systems) features such as emergency braking, lateral control of the car, assistance with speed limits, etc.
When our test vehicles are on the road, their cameras record what’s around them. This means that your image or your vehicle might be captured if you come across our test vehicles.
Data privacy is a core ethical value at Ampere. Ampere takes all the necessary precautions to ensure that your personal data is processed securely and in compliance with applicable regulations, including the General Data Protection Regulation (GDPR).
The data processing we carry out are exclusively focused on the development and enhancement of our driving assistance systems, and do not aim at identifying the people appearing in the images.
How to recognize test vehicles?
Marking placards are displayed on the test vehicles as follows:
Who is responsible for collecting and processing personal data?
Your personal data is processed by Ampere SAS, in its capacity as data controller.
Ampere SAS is located in France, at 122-122 bis avenue du Général Leclerc – 92 100 Boulogne-Billancourt.
The contact details of its data protection officers are as follows: Ampere SAS, Direction juridique – Délégué à la protection des données – 122-122 bis avenue du Général Leclerc, 92 100 Boulogne-Billancourt and dpo@ampere.cars.
What data does the test vehicle collect?
As part of the development and validation testing of ADAS (Advanced Driver Assistance Systems) functionalities, sensors (cameras) of the test vehicle collects videos to reconstruct the environment in which the test vehicles are operating.
The images collected in this context are time-stamped and include the geolocation information needed to understand when the data was captured (including to know the light conditions and weather) and what kind of road was taken.
For what purposes and on what legal basis is my data collected and used?
The data collected in this context are processed for the sole purpose of constituting a dataset for the development and improvement of driver assistance systems (referred to as “Advanced Driver Assistance” or “ADAS”).
This processing is based on Ampere’s legitimate interest to continuously improve driver assistance services contributing to road safety, to fulfill relevant regulatory and standard requirements for car manufacturers, as well as to ensure the performance and reliability of systems integrated into vehicles.
In order to ensure that the data processing fully respects the rights, freedoms and interests of the data subjects, Ampere has put in place a series of guarantees to:
1) restrict access to collected data to certain predefined uses requiring such access.
2) limit data processing to videos that have been previously “blurred” (faces and license plates are no longer visible), except when it is proven that access to the data that has not been blurred is necessary.
3) be completely transparent to individuals about the collection of this data by test vehicles and provide mechanisms for you to obtain details of such processing and exercise your rights (see below).
How long is my data stored?
The video data will be processed and stored for the duration of the development and improvement process mentioned above.
The data is retained throughout the development and update phase of the ADAS, then for three years after the end of the planned evolution of the electronic platform, to ensure the quality of the tests carried out on the systems.
Training, awareness and confidentiality commitments of employees
All Ampere’s employees, Renault Group’s employees, service providers or partners who are authorized to participate in data processing are informed, trained and contractually bound not to disclose any personal data to a person who does not have the right or need to access it.
Can my data be shared with third parties?
Your data may be shared in limited, well-defined cases. The solution providers involved in processing vary according to the tests carried out.
| Entities | Need |
| Ampere SAS | Use data to develop and improve vehicle system functionalities. |
Can my data be transferred outside the European Economic Area?
Wherever possible, your data is processed within the European Economic Area (EEA). However, as some of our service providers or their subcontractors are located in countries outside the EEA, your personal data is processed in these countries. Some of these countries may have regulations on personal data that differ from those of the European Union. In such cases, we take particular care to ensure that the transfer complies with the applicable regulations, and put in place safeguards to ensure a level of protection of your privacy and fundamental rights equivalent to that offered by the European Union (in particular through the use of the European Commission’s Standard Contractual Clauses). We can provide you with further information about these transfers (including the European Commission’s standard contractual clauses) on request to the address given in the “What rights do I have to this data?” section.
What rights do I have to this data?
You have the following rights regarding this data. For more information on your rights: https://www.edpb.europa.eu/about-edpb/faq-frequently-asked-questions/what-are-my-rights-under-gdpr_en
| Rights | Description |
| Right to be informed
|
You can ask us for details on:
– The purpose of processing your data. – The categories of data processed. – The recipients of your data. – The length of time your data will be kept and the criteria explaining why this length of time has been chosen. – The possible existence of transfers to third countries and the guarantees adopted by Ampere to protect your data in this context.
Please note that no profiling is conducted and that the processing does not lead to any automated decision concerning you.
|
| Right of access | You can ask us if we hold any data about you and request that we provide it to you in order to verify its content. |
| Right to object | You may exercise your right to object to the processing of your personal data, for reasons relating to your particular situation, and to request its deletion. |
Finally, you have the right to lodge a complaint with the CNIL about the processing of your personal data. We encourage you to contact us before making any complaint, so that we can do our best to respond to your request.
How to exercise your rights
We remind you that we have no way to identify you on images automatically. The purpose of the processing is not to film you but only to film the vehicle environment.
You may find yourself in the camera’s field of view at any given moment as the vehicle passes, and your image may be captured incidentally. To guarantee the transparency of this processing and the full respect of your rights, Ampere has set up a procedure to handle access requests manually, based on the information at its disposal.
To exercise your rights and enable us to retrieve any images relating to you, your request must therefore include the following information:
| Data | Justification |
| Date, time and location of the encounter with the vehicle | To identify if and which vehicle is involved |
| Length of the encounter | To identify the length of the segment to be analyzed |
| Description of the encounter (including your position relative to the vehicle) | To identify the cameras in the segment that may have filmed the person concerned |
| Description of your silhouette and, if possible, any features that help to distinguish you at the time the image is taken | If necessary, to identify whether the person is present in the images |
| Model and color of your vehicle | Where applicable, if your vehicle was filmed |
How to contact us
To contact us or to exercise any of your rights, you may contact us, exclusively by e-mail and providing proof of your identity, at the following address road-test.privacy@ampere.cars