Improving Road Safety
Last updated: 04/11/2022
DATA PROCESSING STATEMENT
It is important to Netradyne, Inc. (“Netradyne”, “we”, “our”, “us”) that we create and maintain public trust in handling your personal data. We provide our products and services to business customers, but we do so with the individuals’ rights and needs in mind. This data processing statement (“Statement”) provides information about how Netradyne collects and uses your data when your video footage is collected by our business customer’s vehicles.
Netradyne is a company headquartered in the United States. Our company goal is to promote safe driving behaviors and improve road safety through our novel technologies. These goals require an in-depth understanding of a vehicle’s driving environment, so our business customers use our Driveri™ device that includes a number of sensors and either 2 or 4 cameras to record such environment. Netradyne’s technology can assess distracted driving behaviors and traffic in and around the vehicle to identify proactive and risky distances, traffic violations and road events that are difficult to detect to correct unsafe and illegal actions. You can find out more about us and our products and services here.
Under European and UK data protection laws, for the vast majority of data processing conducted by Netradyne, Netradyne is acting as a “data processor” on behalf of its business customers and in compliance with our legal and contractual obligations with our business customers. As the data controller, our business customer is responsible for complying with laws that may require notice, disclosure or consent related to the transfer of personal data to Netradyne. Netradyne enters into agreements with our business customers that legally require Netradyne to protect the personal data we receive or are directed to collect, and use it only to provide our products and services to the business customer. For more detailed information, please reach out to the business customer directly. Netradyne is not responsible for the data protection practices of its business customers, which may differ from those set forth in this Statement.
A very small fraction of data collected, however, will enter Netradyne’s machine learning technology for training purposes (as further described below). For such machine learning activities, and to the extent Netradyne is processing personal data, Netradyne is acting as the “data controller”. This Statement provides information specifically about how Netradyne collects and uses your data for training its machine learning models (data controller as applicable) when your video footage is collected by our business customer’s vehicles.
Information Collected And How We Use It
Netradyne’s Driveri device is equipped with various sensors (such as inertia and GPS) and video cameras.
The video recordings are used to create static and dynamic traffic objects. These can be roadblocks, cars, motorcycles, bicycles, etc. with their individual position and movement in relation to the Driveri-equipped vehicle as well as the position and movement of pedestrians. Recordings of individual road users, license plates or other personal data may be contained in these video and audio recordings.
The video and sensor data are used to detect and interpret road users and general traffic situations. In the later evaluation of the recordings, the video and sensor data are used to develop and improve the algorithms for the driving system. Only a small fraction of video data will enter Netradyne’s machine learning; and furthermore, the presence of personal data within the video data, such as in the form of discernible license plates or pedestrian faces, is incidental to the machine learning purposes.
In particular, the data is entered into the machine learning for the purposes of (a) testing and training Netradyne’s perception engine’s ability to automatically detect pedestrians, (b) to test and train Netradyne’s perception engine on specific aspects of the visual scenes that Netradyne’s camera systems encounter, and (c) develop, validate and refine the software that will operate on the Driveri device. For example, Netradyne collects examples of images containing pedestrian detection failures so that we can train the perception engine. Over time, the perception engine will learn to automatically detect a pedestrian (as a category of data type) in images where it previously could not. In addition, it is rare that the images are sufficiently clear and close for a specific person to be identifiable. Further, our system is not configured to personally identify a natural person or data subject, and Netradyne does not associate the training data with any other identifiable information as this is not necessary for the improvement of the system. All traffic objects are only categorized as street signs, cars, motorcycles, pedestrians, etc. In the example image below you may see the recordings of other vehicles and pedestrians in front of a Driveri-equipped vehicle. They are only recognized as “persons” or “cars” by the algorithm and are classified in such way. The images are not used to identify the unknown pedestrians, the different car models or their drivers. The example image also illustrates the license plate and pedestrian face blurring that is applied by Netradyne as part of its provision of services to its business customers.
Legal Basis For Processing
The legal basis for the collection and processing of these video recordings of the surroundings of the Driveri-equipped vehicles (including the recording of pedestrians and other drivers) is Netradyne’s legitimate interest to improve the accuracy and functionality of the Driveri device to improve road and fleet safety. Data collected by the Driveri-equipped vehicles is used by Netradyne to develop and validate the algorithms for different functions of safe driving.
In certain circumstances, our legal basis for the processing may be our legal obligations, for instance, to establish a defense in case of litigation or to comply with legal obligations, in particular with regulatory requirements.
Data Storage And Retention
We retain the personal data we collect from you for as long as necessary for the intended purposes. When we have no ongoing legitimate interest or legal obligation to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives) then we will securely store your personal data and isolate it from any further processing until deletion is possible.
For further information, please contact us (see the “How to Contact Us” section below).
Data Sharing And International Transfers
Netradyne only shares your data with (a) our affiliates within the Netradyne corporate group and companies we may acquire in the future when they become part of the Netradyne corporate group, to the extent such sharing of data is necessary for the purposes described above, and (b) a small core of third-party service providers that support our machine learning activities for the purposes described above.
We may disclose your data if required to do so by any competent law enforcement body, regulatory, government agency, court or other third-party where we believe disclosure is necessary to comply with applicable law or regulation, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
We also reserve the right to disclose your data that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our Driveri device and any facilities or equipment used to make our Driveri device available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
In the event that we transfer personal data from the UK or the European Economic Area (“EEA”) to countries which have not been determined to have an adequate level of data protection, we use a variety of legal mechanisms to ensure adequate level of protection, including entering into the UK or EEA Standard Contractual Clauses, with appropriate technical and organizational security measures to ensure that your personal data is processed in accordance with applicable data protection standards.
For further information, please contact us (see the “How to Contact Us” section below).
Your EEA And UK Rights
Individuals located in the EEA and UK are generally entitled to claim certain data protection rights from data controllers, including the following:
- Access to or deletion of the personal data.
- Object to processing or request the restriction of the processing of the personal data.
- Complain to a data protection authority about the collection and use of the personal data.
Netradyne does not engage in any automated individual decision-making with your personal data.
To exercise your rights before Netradyne please email us at firstname.lastname@example.org or email@example.com (to contact our DPO) or see the “How to Contact Us” section below for further contact details (including our EEA and UK representative’s contact details).
Note, however, that Netradyne may not be able to identify an individual in the training data, directly or indirectly and therefore your individual rights may not apply, particularly because only a small subset of the total data collected is used for training purposes. In any case, Netradyne will review and process right requests on a case-by-case basis and in accordance with our obligations under applicable law.
If you wish to complain to a data protection authority about the collection and use of the personal data, please contact your local data protection authority. Contact details for data protection authorities in EEA and UK are available here.
Changes To This Statement
Netradyne may change this Statement from time to time. If we make any changes to this Statement, we will post an amended version and change the “Last Updated” date above.
How To Contact Us
If you have any questions relating to this Statement or our use of your data, or if you wish to lodge a complaint about our privacy practices, please find the contact details of our EEA and UK representative below. You can also email us at firstname.lastname@example.org
In the EEA by registered post (our EEA representative):
Lionheart Squared (Europe) Limited (FAO Netradyne)
2 Pembroke House
Upper Pembroke Street 28-32
In the UK by registered post (our UK representative):
Lionheart Squared Limited (FAO Netradyne)
17 Glasshouse Studios
Fryern Court Road
Hampshire, SP61QX UK
You may also contact Netradyne’s Data Protection Officer:
Netradyne DPO: email@example.com
The Driveri-equipped vehicles are marked with the following or similar stickers, which are attached to the exterior of the business customer’s vehicles: