Applied Intuition Bystander Privacy Notice

Applied Intuition, Inc. (“Applied”, “we” or “us”) is a software company committed to developing the next generation of safe and intelligent vehicles. 

This Privacy Notice applies to personal information that Applied incidentally collects and processes about pedestrians, cyclists, other road users and/or bystanders (collectively “Bystanders”) via external sensors and cameras on data collection vehicles, including those that use advanced driver-assistance systems (“ADAS”) and automated driving systems (“AD”) (collectively “data collection vehicles”) in the European Economic Area (EEA) and/or United Kingdom (UK). 

If you are a Bystander, this notice is intended for you. We want you to understand how your information might be processed in connection with our data collection vehicles and be assured of our privacy practices. 

For information about how we process personal information that we may collect through our website or in connection with any events or conferences that we operate, please refer to our Privacy Policy. 

If you have a question or concern about our use of your personal information as described in this Bystander Privacy Notice, please email: privacy@applied.co.

Quick links

To access a specific section of this Privacy Notice, please click on the relevant link below.  Otherwise, please continue reading if you wish to review this Privacy Notice in full.

• Collection of information 
• How we preserve your privacy with anonymisation 
• Why do we need this information?
• Disclosure of information 
• International transfers
• Your rights 
• Data Retention 
• Updates
• How to recognize one of our data collection vehicles
• Additional information for individuals in the EEA/UK and Switzerland

Applied operates data collection vehicles on public roads. These data collection vehicles are fitted with cameras and sensors that automatically, and in real time, collect information and images about their physical surroundings (such as road signs, road markings, Bystanders, buildings and other stationary objects (collectively “Sensor Data”) to allow Applied to build software to enable autonomous vehicles to “see” and safely navigate the world around them. 

The Sensor Data that Applied collects may incidentally include some or all of the following categories of information about Bystanders when they are in the vicinity of a data collection vehicle:

• Images and video footage: Data collection vehicles may collect images or video footage of you when crossing the street, waiting at traffic lights or walking in the vicinity of a data collection vehicle.
• Vehicles and vehicle license plates: Data collection vehicles may collect images or videos of the vehicle you are driving or in which you are a passenger, which may include its licence plate number, as it approaches or passes your vehicle.
• Location data: Data collection vehicles may  collect information about your location through a combination of GPS of the data collection vehicle and your relative proximity to the vehicle as they approach or pass you using lidar sensors, as a means of understanding proximity and maintaining a safe distance.
  

Applied collects Sensor Data to hard drives that are installed in our data collection vehicles. Once a data collection vehicle has completed its journey, Sensor Data is uploaded from the hard drive to Applied systems (which if you are in the EEA will be limited to Applied systems located in the EU) where it undergoes data processing to anonymize it of any personal information before it is used by Applied. Once it has undergone anonymization, the raw, non-anonymized Sensor Data is deleted from Applied systems and the data collection vehicle hard drives.

Applied uses anonymized Sensor Data for the following reasons:

• To safely operate our automated vehicles: We use Sensor Data to safely operate our automated vehicles in real time i.e., to detect and interpret road signs and road markings in accordance with applicable highway codes and rules and to avoid Bystanders and other physical obstacles in the road.
• To develop, train, test and improve our ADAS and AD systems: We use anonymous Sensor Data to develop, train, test and improve the software and algorithms that operate our ADAS and AD systems in automated vehicles. For example, training them to recognize and understand what a particular road sign means, to detect pedestrians or other vehicles on the road, including using anonymized Bystander images, and other input signals that indicate the proximity of a Bystander to the vehicle.

Applied will only disclose non-anonymized Sensor Data to the following categories of recipients: 

• To our group companies: where this is necessary to help us to anonymize Sensor Data.
• To service providers: that we may engage to provide services that help us to anonymize Sensor Data.
• To competent authorities: where we believe it is necessary to exercise, establish or defend legal claims, to protect the vital interests of any person, or to comply with an order or request from any competent court, regulator, law enforcement agency or government authority.

Applied group companies and service providers operate in various countries around the world including the United States, Europe, South Korea, and Tokyo. 

For these reasons, Sensor Data may be transferred to countries other than the country in which you reside. However, Applied does adopt measures to limit international transfers of Sensor Data, particularly in respect of Sensor Data collected in the EEA as outlined under the “Additional information for individuals in...” heading below. 

Applied will take all necessary measures to ensure that Sensor Data is protected in accordance with this Privacy Notice and that any such transfers are lawful.  

Some countries may have specific requirements that apply when we transfer personal information internationally. Where this is the case, the requirements that apply and measures we take to comply with those requirements (where applicable) are described further under the relevant “Additional information for individuals the EEA/UK and Switzerland” heading below.

Data protection laws give individuals rights with respect to the collection and use of their personal information. Depending on the laws that apply in your country and to which we are subject, these may include the ability for you:

• to request access to, correction of, deletion of, or portability of personal information that we process about you,
• to request that we restrict processing, or to object to our processing, of personal information about you,
• to opt-out of marketing communications that we may send you (even if you previously consented to receive these) — for example, by clicking on the unsubscribe link in any marketing emails we send, 
• to not be subject to wholly automated decisions if these have legal effects on you or similarly significantly affect you, and
• if our processing is based on your consent, to withdraw your consent to our processing (although this will not affect the lawfulness of our processing prior to your withdrawal).

Please contact us using the details provided in this Privacy Notice if you wish to exercise any of these rights in relation to the non-anonymized Sensor Data that we process.  We will fulfil any such requests in accordance with applicable data protection laws.  

In addition, you also have the right to complain to your local data protection authority about our use of your personal information.  However, while you are not required to do so, we ask that you contact us first to give us the opportunity to address your concerns directly before speaking with your data protection authority.

As outlined above, Applied collects and retains Sensor Data only for as long as is necessary for Applied to upload it from hard drives in data collection vehicles and anonymize it. This takes up to 28 days. Once anonymized the non-anonymized Sensor Data is deleted.

Our data collection vehicles are equipped with various sensors typical for development of ADAS and AD (e.g., lidars, cameras and radars) and marked with a QR code and our company name.

The QR code will link you directly to this Privacy Notice, allowing you to resurface this information more easily if you are within the vicinity of one of our data collection vehicles.

We may update this Privacy Notice from time to time in response to changing legal, regulatory, or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. 

To see when this Privacy Notice was last updated, please see the "Last Updated" section at the outset of this Privacy Notice.

If you are in the EEA or UK, then please note the following additional information:

1. Data controller

The data controller of your personal information is Applied Intuition Inc.  You can contact us at privacy@applied.co. 

2. EEA/UK representatives 

• Applied’s representative in the EEA is Applied Intuition GmbH who can be contacted at privacy@applied.co.  

3.  Our lawful basis

We collect and process Sensor Data on the basis of:

• Our legitimate interests; namely to create anonymous Sensor Data to develop, train, test and improve our ADAS and AD software, all of which is intended to contribute to the collective improved safety of our public roads.  

4.  International transfers

Applied collects Sensor Data on hard drives in data collection vehicles in the country in which that particular vehicle operates. For data collection vehicles that operate in the EEA and/or UK, Applied will anonymize the Sensor Data in the EEA and/or UK. Only anonymized Sensor Data is transferred to group companies and/or third party service providers that operate in countries other than the country in which you reside. 

If Applied transfers your personal information to a country outside of the EEA (for EEA residents) or the UK (for UK residents), it will ensure that any such transfers are compliant with EU and UK data protection law, as applicable.  

In practice, this means that Applied will only transfer your personal information to a non-EEA or non-UK recipient where: (i) the recipient is located in a country that the European Commission has decided is adequate to receive personal information from the EEA or the UK Secretary of State has decided is adequate to receive personal information from the UK (as applicable); (ii) the recipient has signed appropriate contractual terms with Applied that incorporate the European Commission’s Standard Contractual Clauses or the UK Information Commissioner’s International Data Transfer Agreement or International Data Transfer Addendum (as applicable); or (iii) a data transfer derogation applies (for example, where you have consented to the transfer of your personal information).  

If you have further questions about our international data transfers and the specific measures we use in any case, please contact us at privacy@applied.co for further information.

If you have further questions about our international data transfers and the specific measures we use in any case, please contact us at privacy@applied.co for further information.