2. Who is the data controller?
The data controller is Clevon AS, registry code 16472103, address Reinu tee 48, 71020 Viljandi, Estonia, e-mail firstname.lastname@example.org (“Clevon”, “we”, “us”, "our").
3. What personal data do we process?
Clevon is a technology company developing and manufacturing autonomous, teleoperated robot carriers. Our robots are monitored and, if necessary, controlled remotely (teleoperated) via a remote control centre. The robots are equipped with sensors, including cameras, which allow the robot to operate independently and to provide information to the remote driver. The screens in front of the remote operator display a real-time video feed of the traffic environment around the robot, including nearby road users, vehicles and their registration plates, etc. Video recordings may also be stored and used in later analysis to improve our teleoperation and autonomous driving technology.
Depending on the location of an individual relative to a Clevon robot, the processed data may potentially include:
4. For which purposes is the data processed?
Clevon may process personal data for the following purposes:
5. What is the legal basis for processing data?
The principal legal basis for the processing of data is a legitimate interest in accordance with Article 6 (1) (f) GDPR.
Clevon's legitimate interest lies in the development and testing of remotely controlled, autonomous robot carriers. The transmission of video from the robot's cameras to the remote control station is a key element of this control system in terms of safety, ensuring remote monitoring, support and direct control of the robot. As this technology harbors the potential to improve overall road safety and reduce accidents, development and testing also serve the long-term interests of the wider public.
The likelihood that the use of cameras in this case would allow a particular data subject to be identified or for anyone's right to privacy to be breached is minimal. The aim of recording video is not to capture or identify any specific person and appearing on the video feed can only be incidental. During our development and testing process, we never use software that would allow for the identification of anyone from a video image. The robots’ cameras are not of a stationary nature, minimizing the risk that the cameras would consistently or repeatedly have the same person in their field of view – in other words, the risk of profiling. If there is an increased risk of systematic monitoring of certain areas, such as in the context of driving fixed routes due to conditions imposed by regulatory operating permits, we take special precautions, such as minimizing video storage time.
In certain cases, the legal basis for the processing of data may also be compliance with a legal obligation pursuant to Article 6 (1) (c) GDPR.
We may be obliged under national or European Union law to transfer data to competent authorities for the purposes of determining the circumstances of an accident and assessing the continued compliance of the robot/driving system with applicable technical requirements. In this case, any transfers shall be limited in scope to the data relevant to the particular case.
6. Where do we store the data?
7. With whom may we share the data?
We always treat data with care and confidentiality. Transfers of data may take place only to the extent described herein and to designated recipients:
8. How long do we store the data?
Video data recorded during normal operation is stored for the purposes of further development of the autonomous driving functionalities and the robots’ perception of their surroundings, enabling us to continuously improve the safety and capability of our robots in traffic. It may also be stored for the purpose of determining the circumstances of an accident involving a Clevon robot carrier and for complying with legal obligations. Video data that is not necessary for the purpose or which has achieved its intended purpose is deleted thereafter.
Video data recorded during reduced mode (lower video quality) or recording-only mode (activated when the robot is stationary) is stored on board the robots and not transferred to servers. This data is automatically erased after 2 or 15 days respectively.
9. Your rights as a data subject
In accordance with the GDPR, you, as a data subject, have the following rights:
10. Exercise of rights and contact
Please contact Clevon at email@example.com to obtain more information about data processing, to exercise your rights or to file a complaint.