Data protection regulations - Testing Phase for the Development of Autonomous MOIAs
A.1. Personal data will be processed as part of the test phase. In addition to the General Privacy Policy | MOIA, the following applies.
A.2. The following personal data is processed in the context of participation in the test phase in accordance with Art. 6 (1) (b) GDPR and Art. 9 (2) (a) GDPR for the performance of the contract or in accordance with Art. 6 (1) (a) GDPR for the purpose of conducting the voluntary video interview. In addition, personal data is processed for product development and improvement purposes in accordance with Art. 6 (1) (f) GDPR.
A.3. Interior video data and vehicle operating data: Training Cabin.ai to detect objects and calibrate the camera. The camera images are used to train the system so that it can recognize different objects and people. A special focus is on passenger onboarding and offboarding to ensure that the vehicle can drive safely. This includes detecting whether luggage is safely stowed in the vehicle, whether luggage has been left behind and whether there is the correct number of people in the vehicle.
A.4. Testing of image communication with the Fleet Control Center in the event of an event: As part of the test phase, camera images and interior audio signals are transmitted to the Fleet Control Center ("FCC"). This is to review and optimize communication channels and responsiveness in the event of an event. This also includes communicating with the occupants in the event of an incident to ensure their safety and that of the vehicle.
A.5. Contents of surveys (text, audio, video): As part of the test phase, participants are obliged to fill out a feedback form. This data is used to evaluate the user experience to improve the service (e.g. interface to the app, e.g. during onboarding and offboarding, communication in the event of events) and the product (e.g. seats, comfort, sense of security, emergency functions).
Depending on the rating of the driving experience, it is possible that individual users will receive an invitation to a voluntary video interview in order to discuss the evaluation made as part of the questionnaire in more detail with employees of MOIA and ADMT GmbH. We use the contact details (e-mail address and/or telephone number) for the invitation to the interview in accordance with Art. 6 para. 1 lit. f GDPR. The interviews can be recorded with prior consent. The recordings will be deleted after 12 months at the latest.
A.6. Clarification of events: The camera images are used to document and clarify incidents and events. This will help identify the causes of incidents and prevent future incidents. In these cases, the legal basis is also Art. 6 (1) (f) GDPR with the legitimate interest of clarifying an event.
A.7. We process your personal data in cooperation with ADMT GmbH as joint controllers in accordance with Art. 26 GDPR. The ADMT is responsible for the processing of your data in the same way as we are. The ADMT specific privacy policy can be found here.
Contact details of the joint controllers: Mecklenheidestr. 74, c/o Volkswagen Commercial Vehicles, 30419 Hanover
Purpose of joint processing:
The data will be processed for the purposes mentioned above.
Contact point for data subjects:
To exercise your data protection rights, you can contact both companies. We have agreed that MOIA GmbH will serve as the primary point of contact for your inquiries.
A.8. Apart from this, the data will not be disclosed to third parties without prior consent, except in the cases required by law.
A.9. The data will only be processed for as long as it is necessary to fulfil the specified purposes or any additional statutory retention obligations. The duration of the test phase is scheduled for two years.