PRIVACY POLICY IN RELATION TO DRIVES FOR DEVELOPMENT PURPOSES

This Privacy Policy (the "Policy") describes how Ford-Werke GmbH ("Ford", "we", "our" or "us")) uses and discloses the information (your "personal information") collected and processed in relation to drives for development purposes.

In addition to this Policy, some Ford products and services (including some Ford apps) have their own privacy policies which describe in more detail how your personal information is used in a particular context. You can also find out more about what information your vehicle collects and uses by consulting the owners' manual.

What personal data we use?

Ford collects the following personal information in relation to drives for development purposes:

• Video recordings in the environment of the vehicle (up to 360 degrees) including license plates and faces of individuals;
• GPS-Position of the test vehicle including timestamps;
• Speed of the vehicle;
• Information, you provide to use, e.g. in the course of requests.

How do we use your personal information?

We use the personal information to:

• Develop driving assistance technologies;
• Conduct research;
• Fulfil your requests;
• comply with our legal and regulatory responsibilities, to respond to legal process or requests for information issued by government authorities or other third parties, and to prevent and detect crime and fraud, or protect your, our or others’ rights.

Who we share your personal information with

Your personal information may be disclosed to:

• companies or other organisations that we have engaged to provide services on our behalf such as web-hosting companies, mailing vendors, analytics providers, and information technology providers;
• Joint controllers with whom we cooperate and determine means and purposes of the processing together;
• Technology partners and research partners (e.g. universities and institutes of applied research); 
• Other companies of the Ford group if they are processing the data on our behalf or use the data for research purposes;
• companies or other organisations where you have asked us to or agreed that we may share your personal information with them;
• professional advisors; 
• any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues; or
• any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Policy.

Transferring your personal information internationally

Your personal information will be treated in accordance with UK law concerning data protection and may be transferred within the European Economic Area ("EEA"), as well as to countries outside the EEA (including to the USA). When we transfer your personal information outside the EEA we will  put in place appropriate safeguards in accordance with our legal obligations to ensure that your personal information is adequately protected irrespective of the country to which it is transferred. These safeguards may include obtaining contractual assurances from any third party given access to your personal information that your personal information will be protected by standards which are equivalent to those that protect your personal information when it is in the EEA. If you would like to know more about how Ford protects your personal information, you obtain further information upon request.

Retention of your personal information

We keep your personal information in identifiable form for as long as is reasonably necessary to fulfil the purposes for which we collected it and to comply with our legal obligations.  This generally means holding your personal information for as long as one of the following:

• your personal information is reasonably required in order to provide the services you have requested;
• your personal information is reasonably required in order to protect and defend our rights or property (this will generally be the length of the relevant legal limitation period); or
• we are otherwise required to keep your personal information by applicable laws or regulations.

Lawful grounds for the processing of your personal information

The processing of your personal information is based on legitimate interest of Ford according to Art. 6 sec. 1 lit. f) GDPR. As manufacturer, we have a legitimate interest to develop driver assistance technologies, autonomous driving, driving features and services. These serve the improvement of traffic safety and are in the public interest. It is a privileged research activity according to Art. 89 sec. 1 GDPR. The interests of recorded individuals will be protected. Only short and temporary recordings will be conducted, not required multiple captures of already recorded road segments will be avoided, where possible and identification of individuals will not take place unless requested by you to comply with your data subject rights.

Additionally, we have the legitimate interest to ensure that our prodcuts and services comply with regulatory requirements and – if required – to defend and protect our rights or property.

Another legal ground is the compliance with legal or other regulatory requirements according to Art, 6 Abs. 1 Buchst. c) DSGVO.

Privacy by Design

We take appropriate technical and organizational measures to protect your data from unauthorized access during collection, storage, transmission and processing. For this purpose, we have carried out a data protection impact assessment to determine the security measures to be taken and balance our interests in carrying out the drives and the subsequent analysis and your interests as the person affected by the recording.

However, pseudonymization or anonymization of the collected data is not possible as the recording of real situations including faces and license plates is necessary to train and test self-learning systems. We therefore require unaltered original recordings.

Your rights

You have the right as an individual to find out what information we hold about you and for what purposes, as well as to access that information and make corrections if necessary. You also have the right in some circumstances to object to our use of your personal information, to ask us to restrict or erase your personal information or to request. that your personal information is provided to you in a commonly used electronic format so that you can share it with other organisations. Please note that we can only fulfil some of your rights if you can be identified, i.e. if you provide us with all the information we need to identify the video sequences relating to you, for example the place and time of the recording. Individual rights may also conflict with the rights of third parties or our rights.

Where you have consented to our use of your personal information (please see the section named “Lawful grounds for the processing of your personal information” for further information), you can withdraw your consent at any time.

If you have questions or concerns regarding Ford's use of your personal information, or would like to access the information that Ford holds about you or exercise any of the other rights you have in relation to your personal information, please contact

Ford-Werke GmbH

Ford-Kundenzentrum

Postfach 710265

50742 Köln

Tel. +4922190-33333

E-Mail: kunden@ford.com

Please inform us if you want to update or correct any personal information about you.

Ford and Ford Credit have appointed a Data Protection Officer. You can contact the Data Protection Officer at dsb@ford.com.

If you have a complaint about the way in which we use your personal information we hope that in the first instance you will contact us. You may, however, also make a complaint to the competent data protection authoritiy.

Updates to this Privacy Policy

We may amend this Policy from time to time. If we make substantial or material changes in the way we wish to use your personal information we will inform you accordingly in order to allow you to execute your rights (e.g. object to the processing of your personal information.