Road Testing Privacy Notice

Nanjing Ptah Technology Co., Ltd. is the data controller responsible for the processing described in this notice.

If you have questions about this notice or our data processing practices, please contact us using the details above.

Vehicles participating in ADAS testing may be equipped with sensors used to evaluate and improve vehicle safety technologies. These sensors may collect environmental data from public roads, which can occasionally include images or recordings of people, vehicles, or other surroundings.

This notice explains:

• what information may be collected
• how it is used
• how it is protected
• what rights individuals may have

During testing, the vehicle may collect environmental and operational data, including:

• Sensor Data
  • Camera video recordings
  • Radar and LiDAR sensor data
  • Ultrasonic sensor data
• Location Data
  • GPS location
  • Route and timestamp data

These recordings are intended to capture road and traffic conditions, not to identify individuals. However, people, number plates, or other identifiable elements may be incidentally recorded.

Data collected during road testing is used exclusively for:

• development of Advanced Driver Assistance Systems (ADAS)
• improving vehicle safety features
• validating perception and detection algorithms
• system debugging and performance analysis
• safety and regulatory compliance

Where personal data may be incidentally captured, processing is carried out under Article 6(1)(f) of the UK GDPR – Legitimate Interests.

Our legitimate interests include:

• research and development of road safety technologies
• improving vehicle safety systems
• testing and validation of automated driving technologies

We conduct assessments to ensure these interests do not override individuals' rights and freedoms.

We apply several measures to reduce privacy risks, including:

• collecting only data necessary for testing purposes
• limiting sensor recording areas to the road environment
• implementing facial image and plate number blurring or anonymisation
• restricting access to authorised personnel only

Data collected during testing is retained only for as long as necessary to fulfil research and development purposes.

After this period, data will be:

• securely deleted, or
• anonymised so individuals can no longer be identified

Typical retention periods may vary depending on engineering and safety requirements.

Data may be shared with:

• internal engineering and research teams
• affiliated companies within our corporate group
• technology suppliers supporting system development
• research or validation partners

All third parties are subject to data protection obligations and contractual safeguards.

Where data is transferred outside the United Kingdom, we ensure appropriate safeguards are in place, such as:

• adequacy regulations
• standard contractual clauses
• other legally approved transfer mechanisms

We implement appropriate technical and organisational measures to protect data, including:

• secure storage systems
• encrypted data transfer
• access controls and authentication
• internal data protection policies

Under the UK General Data Protection Regulation, individuals may have certain rights, including:

• the right to request access to personal data
• the right to request correction of inaccurate data
• the right to request deletion where applicable
• the right to object to processing based on legitimate interests
• the right to request restriction of processing

If you believe your data has been handled improperly, you have the right to lodge a complaint with the UK supervisory authority:

We encourage you to contact us first so we can try to resolve your concern.

This privacy notice may be updated periodically to reflect changes in our testing operations or legal requirements.