Test Vehicles

Picture of purple, blue, red and orange lines running horizontally

Privacy Notice Test Vehicles

Magna International Inc. and its affiliates (collectively, “Magna”) are actively developing technologies and systems for an autonomous future. We want to offer enhanced safety, convenience and more comfortable driving experience with our autonomous driving features, new mobility solutions and advanced driver assistance systems (“ADAS”). Please visit our homepage for more information about our products.

For the development and testing of our ADAS products we make use of test vehicles, which record the surrounding vehicle environment. If you encounter one of our test vehicles (or those of our authorized business partners), it may collect your personal data. This Privacy Notice (“Notice”) describes how we process your personal data (or “personal information” or “personally identifiable information,” within the meaning of applicable privacy and data protection laws in your jurisdiction) collected by our test vehicles as part of our research and development activities. Where required by law, this Notice serves as our notice at collection. This Notice applies only to personal data collected by our test vehicles (or those of our business partners).

1. Which personal data are processed and for which purpose are we using them?

Our test vehicles may be equipped with various sensors (such as Radar, LiDAR and ultrasonic sensors) and video cameras recording the surrounding vehicle environment. If you see one of our test vehicles, these sensors may collect the following categories of personal data about you: general location data; electronic, visual, or similar data (namely, photos and videos of people, road users, and vehicle license plates).

We process each of the above categories of personal data for research for technological development and demonstration purposes, i.e. to develop, validate, enhance and improve ADAS technologies. Such technologies are used for example to recognize traffic signs, categorize traffic participants and other objects near a vehicle and act as a driving aid. The processing will allow us to train and re-validate the algorithm used to determine whether it correctly assesses and reacts to objects encountered while driving. While certain data may be recorded and processed, in no instance it is our intention to determine your identity or uniquely identify an individual. However, we may use personal data to verify your identity if you make requests under this Notice. We also use data as otherwise permitted by law.

We may aggregate your data with others’ data, or process your data to create de-identified or anonymized data (within the meaning of applicable privacy and data protection laws in your jurisdiction). We may use such data for any purpose, unless prohibited by law. We will not attempt to re-identify such data, except as permitted or required by law.

2. What is the legal basis for the collection and processing?

Unless applicable law is not directly providing a legal basis, the collection and processing is based on our legitimate interest (pursuant to applicable privacy and data protection laws in your jurisdiction) of developing ADAS technologies to increase general road safety. In addition, our development activities (and related required processing) is in the interest of the individuals themselves as it is enabling us to provide technologies offering convenience as well as more comfortable driving experience.

3. Who may receive my personal data?

In specific cases, each of the above categories of personal data can be made available to or accessed by development partners, service providers (e.g. IT service providers, hosting providers, data annotation partners) and/or other authorized parties (“Authorized Persons").

The personal data may only be shared on a "need-to-know" basis with Authorized Persons, i.e. each Authorized Persons will only receive data that is necessary and relevant for them to receive. For example, an Authorized Persons who provide development services for a radar system will only receive limited data access for the purpose of optimizing the algorithm for the radar system. In addition, we enter with Authorized Persons into data processing agreements limiting the use of the data with them.

We may share data if we believe we have to in order to comply with the law or to protect ourselves, including to respond to a court order or subpoena, or if a government agency or investigatory body requests it. We may also disclose and/or provide personal data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of Magna.

When collected through test vehicles, we do not “sell” your personal data, “share” it for cross-context behavioral advertising, or process it for “targeted advertising,” as these terms are defined under applicable U.S. laws. We may share de-identified, anonymized or aggregated data for any purpose, unless prohibited by law.

4. How are your personal data protected?

We have implemented adequate technical and organizational security measures according to the state of the art to protect your data against manipulation, loss, destruction and against access by unauthorized persons. We routinely improve our security measures in line with technological developments, as required by applicable laws.

5. How long do we keep your personal data?

We use the criteria outlined in this section to determine the time your personal data will be retained. Your data will be retained as long as necessary in order to (a) develop new ADAS technology, including safety and security features; (b) improve ADAS technology, including safety and security features; (c) and to verify software or hardware updates. When we no longer need to use your personal data to comply with contractual, statutory, regulatory, or other legal obligations, we will remove it from our systems, and/or take steps to properly anonymize or de-identify it so that you can no longer be identified from it. If we need to keep your information, including personal data, to comply with legal or regulatory obligations to which we are subject, e.g., statutory retention periods or legal proceedings, we will retain the information in accordance to established retention periods and policy.

6. What rights do you have and how can you assert your rights?

Depending on applicable laws within your jurisdiction, you may have certain rights, such as those described below. For instance, California, Colorado, and Connecticut residents in the US, as well as EU residents can make the requests outlined below. Please note that these rights might be limited under applicable national and state laws. We will not discriminate against you because you made any of these requests.

Rights of knowledge and access

You may have the right to obtain confirmation from us as to whether or not we process your personal data. If so, you may have the right to request access to that personal data. The information you may be permitted to access includes the purposes of our processing, the categories or pieces of your personal data we have processed, and the recipients (or categories of recipients) to whom your personal data have been or will be disclosed. However, this is not an absolute right and the interests of others may restrict your right of access in certain jurisdictions. You may have a right to obtain a copy of your personal data which we are processing in a portable and (to the extent technically feasible) a readily usable format. We may charge a reasonable fee for further copy requests based on administrative costs of providing the information.

Right to rectification (i.e. correction)

You may have the right to request that we rectify (i.e. correct) inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to request deletion/erasure ("right to be forgotten")

In certain circumstances, and subject to certain exceptions, you may have the right to request that we erase (i.e. delete) your personal data. Please note that your data may not be deleted in its entirety from our systems, and some may be kept to comply with legal exceptions or obligations. We may also keep an archived copy of your records as required by law or (if permitted in your jurisdiction) for legitimate purposes.

Right to restriction of processing

Under certain circumstances, you may have the right to restrict our processing of your personal data. In such a case, the relevant data will be marked and may only be processed by us for limited purposes.

Right to make arrangements for the storage and communications of data after one’s death

In some jurisdictions you have a right to make specific arrangements for the storage and communication of your personal data after your death, and we will act accordingly. In such case, you may also make general arrangements with a third party, which will let us know about your instructions in due time.

Right to object

In certain circumstances and for reasons relating to your particular situation, you may have the right to object to the processing of your personal data by us and we may be required to no longer process your personal data.

Right to appeal

You may have a right to appeal our decisions concerning your ability to exercise your privacy rights.

How to Submit a Request

You may exercise these rights by emailing us at dataprivacy@magna.com, calling us (in the US) at +1-248-729-2643, or by using this webform. Also note that we may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. If you are submitting a request to appeal a decision, please make sure to mark your request “Privacy Appeal” (e.g., in the email subject line).

How We Verify Your Identity and Authorized Agents

Whether you submit a request directly on your own behalf, or through an authorized agent, we will take reasonable steps to verify your identity prior to responding to your requests. The verification steps may vary depending on the sensitivity of the personal data.

You can designate an authorized agent to submit requests on your behalf. However, we may require written proof of the agent’s permission to do so and may need to verify your identity directly. If you would like to designate an authorized agent to submit a request on your behalf, please email us at dataprivacy@magna.com to verify your identity and provide written proof of permission. Once verified, your authorized agent may act on your behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.

7. Individuals Under 16

The operation of test vehicles is not meant for, or intended to collect data from, anyone under the age of 16. We do not have actual knowledge that we sell or share the personal information of consumers under 16.

8. Changes to this Notice

We reserve the right to update or change our Notice at any time and you should check this Notice periodically. If we make any material changes to this Privacy Policy, we will place a prominent notice on our homepage.

9. Who can you contact?

If you have any comments, questions or concerns regarding this Notice or practices, please send your inquiry via email to dataprivacy@magna.com, or in writing at Magna Electronics Europe GmbH & Co OHG, Kurfürst-Eppstein-Ring 9; 63877 Sailauf; Germany or Magna Electronics Inc., 2050 Auburn Road; Auburn Hills, Michigan 48326 United States, +1 248 729 2643. You can also contact Magna’s European Data Protection Officers by sending an email to dataprotectionofficer@magna.com or in writing at Magna International (Germany) GmbH; Kurfürst-Eppstein-Ring 11; 63877 Sailauf; Germany. You may also use our online form for your inquiry by selecting “Magna Electronics” as the addressee and in regards to “Data Privacy” . Furthermore, if you believe that the processing of your personal data violates legal requirements, you may have the right to lodge a complaint with the competent supervisory authority, if available.