Data Protection Notice of BrightDrive Software Design DWC-LLC for Data Processing in Connection With Research and Development of Self-Driving Sensors and Equipment

BrightDrive Software Design DWC-LLC ("BrightDrive") is a technology company headquartered in Dubai, United Arab Emirates, specializing in self-driving cars software and equipment. Our work includes collecting, processing, and analysing image data of public environments in connection with our research and development in the field of intelligent imaging technologies, mapping, and automated recognition and self-driving systems.

Information on the Responsible Organization

BrightDrive Software Design DWC-LLC

DLC-BC-A3-3-OSD03-085
3rd Floor, A3, Business Centre
Dubai, United Arab Emirates
www.brightdrive.ai

What Data Do We Process and for What Purpose?

• Our test vehicles are equipped with devices which include various sensors, such as LIDAR and radar sensors, as well as video cameras (including audio). These video cameras record the surroundings of the test vehicles to support us answering scientific questions in the field of automated driving. This may also involve recording road users who are within the cameras' field of view, including their image. This is not intended, but it cannot be necessarily ruled out.

• The purpose of these video and audio recordings is to detect traffic objects (such as road markings, traffic signs, buildings, bridges, etc.) and other road users (vehicles, cyclists, pedestrians, etc.) during our test drives, to capture their positions and directions of movement relative to our test vehicle, and to map traffic scenarios correctly in automated driving mode.

• After the test drives are completed, the video and audio data are combined with other sensor data. This enables us to evaluate the driving functions used and the traffic scenarios encountered, as well as to analyse, improve, and further develop algorithms for automated driving.

• These processes help us to operate the automation driving equipment and sensors and to research, test, and develop automated driving functions. This, in turn, serves to increase vehicle and traffic safety.

• The traffic objects and road users recorded by our cameras, such as cars, trucks, cyclists, pedestrians, etc., are only categorized and classified as "cars," "people," etc. The video and audio recordings may contain footage of individuals, vehicle license plates, or other personal data. Identifying people or license plates is not intended and is not performed by our systems.

• On part of presentations, excerpts from the camera footage are shown to exchange information about the current state of research with our research and cooperation partners and to introduce automated driving to a broader public. In these cases, the footage is reviewed beforehand, and recordings without identifiable personal data are selected.

Legal Basis for Processing

The legal basis for processing personal data is our legitimate interest (Art. 6(1)(f) GDPR) in conducting technological research, AI development, and improving data-driven imaging systems.

Where we process personal data as part of research collaborations or projects of public interest (such as advancing AI safety or reliability), the processing may also rely on public interest (Art. 6(1)(e) GDPR).

Data Retention

We store personal data only as long as necessary to achieve the stated research and development purposes. When data is no longer needed, it is securely deleted or anonymized.

How long do we store your data?

We store your personal data for as long as we need it to fulfil our research objectives.

Data Security

We apply state-of-the-art technical and organizational measures to ensure data protection, including:

• Encrypted storage and transfer of collected data.

• Controlled access to systems and datasets.

• Regular monitoring to prevent misuse or unauthorized access.

• Use of anonymization and blurring tools to remove identifiable elements.

Data Sharing and International Transfers

• To develop and validate safe and reliable functions for automated driving, a large amount of sensor data is required, which cannot be collected by a single research institution alone.

• We, therefore, share the data collected by the test vehicles with cooperation partners. Whenever sufficient for the specific research purpose, faces and license plates are anonymized before sharing the footage.

• Our cooperation partners include industry and research partners with whom we collaborate in the field of research and development in automated driving. The transfer of sensor data is subject to strict purpose limitations: Research and development in automated driving. Identifying individuals is neither intended nor permitted as this is not relevant for the research and development of automated driving systems. Only the position and direction of movement of traffic objects and participants are relevant.

• International transfers of personal data outside the European Union/European Economic Area (EU/EEA), including to the United Arab Emirates, we ensure compliance with EU Standard Contractual Clauses and implement appropriate safeguards to maintain EU-level data-protection standards.

• Identifying individuals is neither intended nor permitted under our data-sharing agreements.

Your Rights

In its capacity as a data subject under the GDPR, you have the following rights:

• Right of access (Art. 15 GDPR)

• Right to rectification (Art. 16 GDPR)

• Right to erasure (Art. 17 GDPR)

• Right to restriction of processing (Art. 18 GDPR)

• Right to data portability (Art. 20 GDPR)

• Right to object (Art. 21 GDPR)

Since the identification of individuals is generally not possible or intended in our processing, exercising certain rights may require additional information from you for verification. If you believe you have been recorded by our systems and wish to exercise your rights, please contact us using the details above.

Exercising Your Rights and Complaints

If you want to exercise your data subject rights, please contact us in writing (see our contact details above). You are also welcome to reach out to us if you need additional information or have general questions.