Privacy policy for data processing by Carmeq for test drives

We, Carmeq GmbH (hereinafter referred to as Carmeq), are working on the car of the future. This includes the development and improvement of safety-relevant driving functions such as driving assistance systems.

Driving assistance systems must be able to reliably assess and manage complex scenarios such as driving through construction sites, overtaking procedures and general traffic processes. This requires the use of intelligent algorithms that quickly and correctly evaluate the vehicle's surroundings as recorded by cameras, radar and lidar systems. In order to develop and improve such algorithms, it is necessary to have training data from real traffic scenarios on public roads.

Among other things Carmeq carries out so-called test runs with test vehicles. The test vehicles are clearly marked to be identified as test vehicles.

Hereafter we inform you about the personal data we process during test drives. Should you be affected by the data processing during test drives (e.g. you suspect you have been filmed), we will inform you about how and which rights you can assert.


1. Which data do we process during test drives?

We carry out the test drives with specially equipped vehicles. They are equipped with various sensors and measuring devices as well as video measuring technology.

The cameras of the video measurement technology are oriented towards road traffic. As the cameras record road markings, road signs and the vehicles participating in traffic, it is unavoidable that vehicle number plates and persons are being recorded as well. The recordings of persons and vehicle number plates are personal data.


2. For which purpose and on what legal basis do we process your data?

We process the data collected during test drives exclusively in order to develop, improve and evaluate safety-relevant driving functions. The focus is on the development of driver assistance systems and autonomous (automated) driving. The aim of our work is to reduce traffic accidents and increase road safety.

The processing of personal data in connection with test drives and the development of safety-relevant driving functions is based on these objectives on the legal basis of the legitimate interests of the controller (codified in Art. 6 para. 1 lit. f) GDPR).


3. Who at Carmeq uses this data?

Within Carmeq, the data is only used by those departments that are involved in the development, improvement and evaluation of safety-relevant driving functions.


4. Is the data transferred to other companies?

The development of driving functions such as assistance systems and systems for autonomous driving cannot be handled by one company alone. We therefore work together with various companies. Some of these companies work for us as processors, others as controller that are independently responsible. These companies receive the data processed during trial runs.
Companies that work for us as processors are for example:
  • Companies that are specialised in data evaluation and analysis;
  • Companies that offer hosting services (servers).

Companies that receive data from us as independently responsible controllers are for example:

  • Companies of the VW Group,
  • Service providers and development partners,
  • Universities.

Depending on the individual test drive, we work together with different companies. If you would like to know to whom we send the data of a specific test drive, please get in contact with us.


5. Is data transferred to a country outside the European Economic Area?

As part of the development of features it may be necessary to transmit data to companies in countries outside the European Economic Area. However, we ensure that your personal data is being protected in accordance with the GDPR, for example by concluding so-called standard data protection clauses.


6. Storage period of the data

We store the data collected during test drives only as long as it is needed for development, improvement and evaluation. Upon request, we will be pleased to let you know how long we store the data collected for the development of a driving assistance system.


7. Your rights

You have the right to be informed at any time whether and to what extent we process data concerning you. If data stored by us is incorrect or no longer up to date, you have the right that this data is being rectified. You may also request that this data is being deleted. If, in exceptional cases, the deletion may not be possible due to other legal regulations, the data will only be available for these legal purposes and being blocked for other purposes. The processing of the data can also be restricted if, for instance, you doubt that the processed data is correct. You also have the right to data portability which allows you to obtain a digital copy of the personal data we hold. In order to assert the rights described here, you can contact us at any time using the contact details provided. This also applies if you wish to receive copies of guarantees proving an adequate level of data protection.

Please note that we process the data within the scope of test drives exclusively for the development, improvement and evaluation of driving assistance systems. An identification of persons is neither possible nor intended by us. Accordingly, we may only be able to guarantee your rights under certain circumstances. If necessary, identification is possible based on further information that you can provide us with (e.g. time at which you suspect to have been filmed; date; which clothes you have been wearing). If we can identify you based on this information, we will certainly ensure that your rights are being entirely respected.

If we process your data based on legitimate interests, you have the right to object to the processing of your data for reasons arising from your particular situation at any time.
If you wish to make use of your right of objection, it is sufficient to send an informal message to the contact details mentioned above.

Finally, you have the right to complain to the data protection supervisory authority responsible for us. You may exercise this right with a supervisory authority in the Member State of your residence, workplace or place of suspected infringement. The competent supervisory authority is in Berlin, where Carmeq GmbH has its registered office: The Berlin Commissioner for Data Protection and Freedom of Information, Friedrichstr. 219, 10969 Berlin.


8. Who should I contact if I have any questions or if I would like to exercise my rights?

We, Carmeq GmbH, Carnotstraße 4, 10587 Berlin, are responsible for processing this personal data. If you have any questions, please do not hesitate to contact us at any time. You can reach us at the address provided or at:

Phone: +49 30 3983537-0
Fax: +49 30 3983537-199

You can also contact our data protection officer at any time if you have any questions about data protection in connection with test drives. You can reach him at the above postal address as well as the e-mail address given (keyword: "Attn. Datenschutzbeauftragter").


9. Changes to the data protection declaration

From time to time we update this privacy statement, for example if we adapt our website or if the legal or official requirements Change.


Version: 1.0 / Status: September 2019