Zenuity’s Privacy policy

 

INTRODUCTION

This Privacy Policy describes what personal data Zenuity may collect and for what purposes.

Zenuity processes personal data in accordance with applicable laws and regulations, including the General Data Protection Regulation (GDPR). Zenuity is in its capacity as a so-called “data controller”, responsible for ensuring the lawful processing of your personal data and will at all times take necessary technical and organizational measures in order to protect your personal data.

Zenuity values transparency. Thus, Zenuity wishes to share with you, information on what personal data Zenuity is processing and for what purposes. That is why we encourage you to read through this Privacy Policy, describing Zenuity’s processing of your personal data, and also describing your legal rights.

This Privacy Policy explains how Zenuity process personal data relating to you who;

  • Represent a customer, supplier or other business partner of Zenuity (Business Contact);
  • Visit Zenuity’s website or interact with Zenuity via Zenuity’s digital communication channels, such as social media;
  • Visit Zenuity’s premises; or
  • Apply for a position at Zenuity.

This Privacy Policy also addresses the fact that Zenuity may come to process personal data in connection with the development of Zenuity’s software for advanced driver assistance systems and automated driving. Data collected and analyzed by Zenuity, for the purpose of analyzing various traffic situations, such as footage of traffic environments, may include personal data.

It is important that you read this information, together with any other information that may be provided to you directly, in connection with situations addressed below, or in other situations not specifically addressed in this Privacy Policy.

Zenuity may receive e-mails or other information from third parties, containing personal data about you, and may in such case process such personal data. If required, Zenuity will inform you of such processing separately.

This Privacy Policy will be updated from time to time by Zenuity. If you have questions or concerns about our processing of your personal data, do not hesitate to contact us. Please see contact details set forth below.

 

CONTACT DETAILS

Data Controller – Sweden

Name: Zenuity AB
Company organization No.: 559073-6871
Postal address: Lindholmspiren 2, 417 56 Göteborg, Sweden
E-mail address: privacy@zenuity.com
Telephone No.: +46 (0)31 31 36 000

Data Controller – Germany

Name: Zenuity GmbH
Company organization No.: DE11512191624
Postal address: Konrad-Zuse-Strasse 1
85716 Unterschleißheim
Germany
E-mail address: privacy@zenuity.com
Telephone No.: +46 (0)31 31 36 000
DPO: privacy@zenuity.com

+46 (0)31 31 36 000

Supervisory Authority – Sweden

Name: Datainspektionen
Postal address: Box 8114, 104 20 Stockholm, Sweden
E-mail adress: datainspektionen@datainspektionen.se
Telephone No.: +46 (0)8 657 61 00

Supervisory Authority – Germany

Name: Bayerische Landesamt für Datenschutzaufsicht
Postal address: Promenade 27, 915 22 Ansbach, Germany
E-mail address: poststelle@lda.bayern.de
Telephone No.: +49 (0) 981 53 1300

 

USEFUL DEFINITIONS

“Personal data”– means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing”– means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Data controller”– means the physical or legal entity that determines the purpose and means of the processing of personal data. Zenuity, and ultimately the Zenuity company processing your personal data, is regarded the data controller for the processing of such personal data.

“Data processor”– means the physical or legal entity that process personal data on behalf of a data controller, for example an IT service provider.A data processor may only process the personal data in accordance with the data controller’s given instructions.

 


WHAT PERSONAL DATA, FOR WHICH PURPOSES, AND FOR HOW LONG, DOES ZENUITY PROCESS YOUR PERSONAL DATA?

Zenuity’s processing of your personal data, will be limited to only the appropriate, relevant, accurate and necessary personal data for each purpose. Zenuity will process your personal data only for the specific purposes that such data was collected for.

Personal data that we process, and our purposes for such processing, vary depending on in what context you come into contact with Zenuity. Reading further, you will find information on how Zenuity processes your personal data, depending on your relationship with Zenuity.

 

For Business Contacts

What personal data do we process?

Zenuity may process personal data related to you if you are acting on behalf of a company or organization, that interacts with Zenuity. It may be both personal data provided by you directly to Zenuity and personal data that we receive from the company or organization that you represent, or from a third party involved in the relevant business context.

Personal data Zenuity may process:

  • Your first and last name
  • Other contact details, such as organization/company name and address, e-mail address and phone number.
  • Your title or role.


For what purposes, on what legal basis and for how long?

Fulfillment of contracts between you or your company/organization and ZenuityFor the purpose of being able to fulfill Zenuity’s commitments towards you or your company/organization, Zenuity may, if necessary, process your personal data. The legal basis for Zenuity’s processing of personal data regarding you as a private business, is that the processing is necessary for the performance of our contract, or to take necessary steps prior to entering into such contract. If you interact with Zenuity as a representative for a company/organization, the legal basis for Zenuity’s processing of your personal data is that the processing is necessary for the purpose of Zenuity’s legitimate interest in being able to communicate with a representative for Zenuity’s business partner, and the purpose of fulfiling any contract with the company/organization that you represent. Personal data that Zenuity processes for the mentioned purposes, will not be processed longer than it is necessary for Zenuity to fulfill its contract with you or your organization.

AccountingFor accounting purposes, Zenuity will process information about economical transactions between Zenuity and you or your company/organization. Zenuity may, if necessary, process your personal data in connection therewith. The legal basis for Zenuity’s processing in this regard is that it is necessary to fulfill legal obligations required by accounting legislation. Personal data that Zenuity processes for accountingpurposes will, in accordance with applicable accounting legislation, be stored for up to seven years or as long as applicable legislation otherwise requires.

 

For Website Visitor, Social Media Interaction etc.

What personal data do we process?

When you visit Zenuity’s website www.zenuity.com or otherwise interact with Zenuity via our digital platforms such as our social media channels, we may process personal data about you.

Website visitor –You can generally browse our website without revealing who you are or sharing any other personal information about yourself. For system related and statistical purposes, including improving our website, Zenuity may store certain information on your computer in the form of “cookies” or similar technology. To read more about our use of cookies and the data that we collect when you visit the website, please see ourCookie Policy.

Social media interaction etc. –When you interact with Zenuity via our digital platform, such as our social media channels,we will process personal data made available by you through the specific social media channel (Facebook, Instagram, Twitter etc.).

Personal data that we typically may process is:

  • Your name
  • Your username
  • Your profile picture
  • Your comments and other results of your active engagement


For what purpose, on what legal basis and for how long?

We will process your personal data to understand how our digital platforms and communication channels are used, where our visitors come from and what content is of interest to our visitors. We use this information for our internal analytics purposes and to improve the quality and relevance of our digital platforms and communication channels. We will also process personal data provided to us by you, in order to respond to any questions or inquiries that you may have.

Your personal data will be processed on the basis of a balance of interests, where our legitimate interests are to (i) operate and improve our digital platforms and communication channels and (ii) promote our business and communicate with persons interested in Zenuity and Zenuity’s business.

Your personal data will not be processed longer than necessary with reference to the purposes for which it was collected.

 

For Offices Visitors – Visitor System

What personal data do we process?

When you visit Zenuity’s offices, we will process your personal data. Note, that further information on the processing of your personal data in connection with your visit, will be provided to you in connection with your visit.

Upon entering Zenuity’s premises you will be asked to register your visit in our visitor system. Personal data we will process is:

  • Your first and last name
  • The name of the company or organization you are representing
  • Your e-mail address
  • Your telephone number
  • A photograph of you
  • The time of your registration of your visit
  • Your acceptance (and signature) of our non-disclosure agreement (NDA), which is an agreement between you and Zenuity

For what purpose, on what legal basis and for how long?

We will process your personal data in order to administrate your visit and uphold our high safety and security standards, applicable for all of Zenuity’s premises. In addition, we will also process your personal data for the purpose of keeping a record of the NDA executed within the visitor system.

Your personal data will be processed on the basis of a balance of interests, where Zenuity’s legitimate interests are to (i) administrate your visit, (ii) uphold Zenuity’s high safety and security standards and (iii) keep a record of the NDA signed by you.

Your personal data will not be processed longer than necessary with reference to the purposes for which it was collected. Your photograph will be stored no longer than seven days after your visit. Other personal data will be stored as long as we store the NDA signed by you, which depends on the reason to your visit.

 

For Offices Visitors – Security Camera Surveillance

Zenuity operates a security camera surveillance system within its premises. Note that further information on the processing of your personal data in connection with your visit is displayed on signs on the premises and provided to you by other means upon your visit.

What personal data do we process?

Personal data that we will process is video recordings (no sound) from the security camera surveillance system.

Why, on what legal basis and for how long?

We will process your personal data for the purposes of security, prevention of theft and sabotage and securing evidence in case of events threatening security.

Your personal data will be processed on the basis of a balance of interests, where our legitimate interests are to protect the premises and our assets, to ensure security and to secure evidence. Interests which are not overridden by the interests, rights or freedoms of the persons subject to camera surveillance and storage of recordings.

Your personal data will not be processed longer than necessary with reference to the purposes for which it was collected. Recordings will be stored for a maximum of seven days, unless we have reasons to keep them longer for the purpose of further investigation or securing evidence.

 

For Job Applicants

When you submit your job application to us, you will also submit personal data about yourself. Note that further information on the processing of personal data in connection with your job application will be provided to you upon our receipt of your application.

What personal data do we process?

The personal data that we will process about you can both be information provided by you and information that we choose to collect from recruitment agencies, other third parties engaged by us and potential references.

Personal data we will process is:

  • Your first and last name, other contact details such as address, e-mail address and phone number
  • Information set forth in your cover letter and CV, such as employment history, education, leisure interests etc.
  • If applicable – test results, grades, certificates, references, comments, notes from interviews, employment offer (financial terms).

Note, we kindly ask you to not submit information on references until we ask you to do so.

 

Why, on what legal basis and for how long?

We will process your personal data in order to administrate and appraise your job application. In addition, we will also process your personal data in order to respond to any criticism/claims relating to the recruitment process, if necessary.

Your personal data will be processed on the basis of a balance of interests, where our legitimate interests are to (i) administrate and appraise your job application on the basis of the business conducted by Zenuity and Zenuity’s business needs, and (ii) administrate you application to an advertised position, assess your eligibility and career possibilities, confirm your actual knowledge and employ the right person based on the business needs of Zenuity. Your personal data may also be processed based on our legitimate interest to be able to respond to any future criticism/claims relating to our recruitment process.

Your personal data will not be processed longer than necessary with reference to the purposes for which it was collected. Therefore, Zenuity regularly sorts out and erases information and personal data that is no longer necessary. Your personal data will as a principal rule be deleted as soon as the relevant position is filled. Please note that Zenuity may need to store your application documents for a period of two years thereafter, in order to be able to respond to any possible future legal claims relating to a recruitment process where you have been one of the applicants. If we wish to save you application, in case of other available positions later on, we will ask for you consent to do so.

It is voluntary to apply for an employment and provide us with your personal data, but to enable us to compare your application with the other applicants we will need your complete application documents.

Public Traffic Environment Data

The development of Zenuity’s world-leading software for advanced driver assistance systems and automated driving partly involves collection of data from various traffic situations. The data collected may, as an unintended effect, come to include images and film footage of individuals moving around in the public traffic environment where Zenuity’s data collection takes place as well as vehicles with visible license plates. Zenuity is not interested in and does not in any way attempt to identify the individuals, or other personal data, appearing in such data collection. Zenuity processes the data for the sole purpose of developing its software. The personal data will be processed on the basis of a balance of interests, where Zenuity’s legitimate interest is to develop its software.

The personal data will not be processed longer than necessary for the purpose of the development of the software. Therefore, Zenuity regularly sorts out and erases data that is no longer needed.

 

 

 

TRANSFER OF YOUR PERSONAL DATA  

Your personal data may be submitted to, and processed by, third parties. These may include Zenuity group companies, customers, service providers, banks, legal advisors, auditors, business consultants, agencies, etc. Examples of situations when your personal data may be transferred to third parties is when such action is required due to law, dispute, government request or decision, outsourcing of payroll administration, at your own request, or when required to fulfill a legitimate interest for Zenuity. Zenuity remains the responsible data controller for the personal data provided, while third parties, depending on the circumstances, become either an independent data controller or Zenuity’s data processor. Zenuity has agreements with engaged data processors (processing personal data on Zenuity’s behalf) ensuring that the data processors process your personal data in accordance with what is set forth in this Privacy Policy and in accordance with Zenuity’s instructions.

Your personal data may be transferred to countries outside of the EU/EEA, to Zenuity’s service providers (data processors) outside the EU/EEA, or to other Zenuity legal entities within the Zenuity group. All Zenuity legal entities have by agreement and policies adopted the same procedures and level of protection and security measures, in order to safeguard your data. Accordingly, any transfer of data outside the EU/EEA is made in line with data protection laws. Unless there is another legitimate basis, our international transfers of personal data are based on the EU Commission’s standard contractual clauses.

MISCELLANEOUS

Automated individual decision making/profiling– Zenuity conducts no automated individual decision-making or profiling.

It is voluntary to provide Zenuity with personal data, but if you do not provide your personal data to Zenuity– it may be that we cannot fulfil certain undertakings towards you or your company/organization, or that we may have to restrict your access to our premises etc. If you have any doubts or concerns about leaving certain personal information, please contact Zenuity (see contact details in the beginning of this Privacy Policy) for further information.

YOUR LEGAL RIGHTS

When Zenuity processes your personal data, you have certain rights under law. Please note that the exercising of these rights is subject to certain requirements and conditions set forth in law (GDPR).

Your right to be informed and your right to access

You have the right to receive information about how Zenuity processes your personal data. Thus, we have established this Privacy Policy, which Zenuity encourages you to carefully read.

In addition, you have the right to, free of charge, upon written request receive information about what personal data Zenuity stores about you and how your personal data is used and processed.

You are entitled to request in writing, free of charge, a copy of the personal data that Zenuity has registered about you.

If your request is unfounded or your request is excessive, e.g. should you frequently and within short intervals ask to receive information on or a copy of your personal data, Zenuity has the right to refuse to act on your request, or to charge a reasonable fee which covers the administrative costs of the action requested by you.

Your right to rectification and erasure

In the event that your personal data is inaccurate or incomplete, you have the right to request that Zenuity corrects or removes the personal data, including the right to have incomplete personal data completed.

You have the right to request the erasure of your personal data under certain circumstances (set forth in the GDPR). Provided that your request falls within one of those circumstances, we will erase your personal data.

Your right to object

You have the right to object to your personal data being processed for direct marketing purposes, including profiling analysis made for direct marketing purposes.

If you do not want your data to be used for direct marketing, including profiling analysis, you can notify us by sending an e-mail to privacy@zenuity.com.

Your right to restrict processing

Under certain circumstances (set forth in the GDPR) you have the right to request the restriction of processing of your personal data. In such case, your personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.

Your right to data portability

Under certain circumstances (set forth in the GDPR) you have the right to receive your personal data, which you have provided to Zenuity, in a structured, commonly used and machine-readable format, for transmitting such data to another controller. You may also have the right to request that personal data is transmitted directly from us to another controller, where technically feasible.

Your right to file a complaint

We encourage you to contact us if you have any questions regarding this Privacy Policy or if you are unhappy with the way Zenuity is processing your personal data.

You also have the right to file a complaint with the supervisory authority regarding Zenuity’s processing of your personal data or handling of any inquires related to it. You find the contact details of the relevant supervisory authority above in beginning of this Privacy Policy.