Privacy Policy and Data Protection

FICOSA GROUP (hereinafter FICOSA), in accordance with current legislation on the Protection of Personal Data, informs the users of the website www.ficosa.com (hereinafter the Website) of the Privacy Policy and Data Protection that will be applied in the processing of the personal data Users voluntarily provide when accessing the Website.
Users, by providing their personal data through the Website, and, where appropriate, by marking the relevant acceptance box, expressly accept that FICOSA may process such data in terms of this Privacy Policy and Data Protection clause and for the purposes expressed herein.

FICOSA informs the users of the Website that their personal data can only be obtained for their processing when they are appropriate, relevant and not excessive in relation to the scope and the specific, explicit and legitimate purposes for which they were obtained. They will be deleted when they are no longer necessary or relevant for that purpose, or when requested by the owner in the exercise of their right of deletion.

FICOSA expresses its commitment to comply with current legislation regarding data protection and other applicable legislation at all times.

The personal data provided will be processed in accordance with the following:

INFORMATION ON PERSONAL DATA PROTECTION (In compliance with EU Regulation 2016/679 on Data Protection)
Data Controller	See Companies that are part of FICOSA Group
Purposes	The collection and processing of personal data has the following purposes: answer your questions, send you, by traditional and electronic means, information about our services and products, apply for a job, any other service related to FICOSA’s activity we may consider of interest, for statistical purposes in order to analyse User behaviour and trends and analyse how to improve the services we provide, and detect and investigate fraud, as well as other illegal activities and potential breaches of our Privacy Policy, Legal Notice and/or Terms and Conditions of Use.
Legitimation and conservation	The legal basis for data processing is the consent granted by Users when providing their data or by marking, where appropriate, the relevant acceptance boxes. If they do not provide the necessary data for these purposes, we will not be able to provide our services. The data will be kept while the relationship is maintained and their deletion is not requested and always in compliance with the statutory limitation periods that may be applicable.
Transfer recipients	In the event that data transfers are foreseen, Users will be informed in advance so they can oppose to said transfer by marking a box.
Rights of the interested parties	You can exercise your rights of access, rectification, deletion, portability and limitation or opposition by writing to FICOSA to the email address
	Users have the right to withdraw their consent.
	Users have the right to complain before the Supervisory Body (Spanish Agency for Data Protection www.agpd.es).

Users will be solely responsible for the accuracy of the data they provide to FICOSA.

Unless specifically stated otherwise, providing all the requested data will be considered necessary, because without them, FICOSA will not be able to provide the services requested by users.

FICOSA has adopted the necessary technical and organisational measures to guarantee the security of the personal data contained therein and to prevent their alteration, loss, processing and unauthorised access, given the current state of technology, the nature of the data and the risks to which they are exposed.

Any changes made to the Privacy Policy and the information management practices will be published in a timely manner and FICOSA may add, modify or delete said Privacy Policy when it deems necessary.

FICOSA will, in no case, modify the policies or practices to make them less effective in protecting the personal data of our users that have been stored previously without the prior consent of the affected parties.

Privacy policy for the video recordings in the context of the development and improvement of driving assistance functions and products.

PROCESSING CONTEXT.

FICOSA is a private entity focused on the research, development, manufacturing and commercialization of cameras and advanced vision, security, connectivity, and efficiency systems for the automotive and mobility sectors.

Currently, FICOSA is promoting the usage and development of technologies that improve autonomous driving systems, which requires researching and developing them in a real environment. Therefore, it will imply the capture of images and other data on public roads through vehicles with sensor systems for data collection (cameras, LiDAR, GPS and/or timestamp), as well as storage systems for the said data.

Consequently, the process of collecting samples will imply the eventual capture of pedestrians, vehicles, vehicle license plates raw data, and/or any other element that is located in the public environment, and simultaneously passes during the journey made by FICOSA vehicles.

Likewise, the usage of data captured in a real environment is essential to capture a wide and diverse catalogue of information, which reflects the real situation that a vehicle may face in operation, if it is possible. The purpose of the caption is avoiding mistakes or dysfunctions in autonomous driving systems.

In this regard, the usage of image samples is limited to carrying out an analysis and identification of these as categories of existing “objects” that a vehicle may encounter in a real driving context on public roads. And so, subsequently the technologies installed in autonomous or semi-autonomous vehicles can differentiate elements from each other (for example, pedestrians versus trees, sidewalks, vehicles, etc.).

Furthermore, the data captured through the sensor systems is essential for the technological systems development, since they allow the vehicle to be located within the environment, reconstruct the trajectory in space-time and the scene with the real elements of the captured environment. In no case it will be used to identify data subjects, locate them, or perform permanent geolocation.

Due to the aforementioned, it is not possible to carry out the activities described in a more limited environment, nor using simulated data. Thus, the processing and subsequent use of raw data is strictly necessary.

Otherwise, it is not possible to carry out research and development of autonomous driving technologies and systems that guarantee an adequate level of safety in the vehicles in which they are subsequently implemented.

Though the processing of personal data does not constitute the main activity of information processing, since those affected may be directly identified or identifiable, in accordance with the provisions of Article 4.1 GDPR, we inform you that your personal data will be processed in the following terms:

INFORMATION REGARDING THE PROCESSING OF PERSONAL DATA
Data Controller	Name: Ficosa Automotive, S.L.U. VAT Number: B65435117 Address: Calle Gan Vía Carles III, 98, 08028 Barcelona Email: dataprotection_spain@ficosa.com
Data subjects affected	Pedestrians. Vehicles owners.
Categories of personal data:	Identifiable Personal Data: pedestrians and licence plate images. Additional Personal data captured by the sensors (LiDAR, GPS and/or timestamp – associated to temporality, position, class and/or coordinates-).
Purposes and processing operations	Personal data are processed for the following purposes: Functions and products development, validation and implementation for autonomous driving assistance systems. Carrying out scientific and commercial research on autonomous driving assistance products and services to guarantee improvement in road safety. For the achievement of the said purposes, FICOSA will carry out the following processing operations: Public road recordings and storage of the images captured. Object labelling for the validation and its correspondence with reality. In any case, we inform you that the labelling does not imply automated decision-making. It is guaranteed that a human will participate in this process. Functional testing of the technology that will be implemented in autonomous driving systems. Destruction of the defective data captured by the cameras.
Lawfulness of the processing and storage period	The lawfulness of the processing is FICOSA’S legitimate interest consisting of the development and technical improvement of advanced vision, safety, connectivity, and efficiency systems products for autonomous vehicles.
Lawfulness of the processing and storage period	Your personal data will be stored for the essential period time to carry out the research, development and testing necessary to achieve safe and efficient products. In any case, personal data will be stored in compliance with the time limits stated in the legislations that may be applicable to FICOSA.
Recipients and international data transfers	It is not foreseen to transfer your personal data to third parties, except to Courts and Tribunals, when it is necessary to comply with legal obligations. Furthermore, FICOSA will collaborate with processors that will process your personal data on behalf of Us, for the purpose of providing services. FICOCSA follows strict supplier selection processes to comply with data protection obligation, including the signing of Data Processing Agreement in accordance with Article 28 GDPR. Specifically, FICOSA Group companies will provide services, as well as, but not limited to technological services providers. Some of FICOSA’s providers may be located in third countries outside the European Economic Area, which may imply an international data transfer. In accordance with the provisions of TITLE V GDPR, FICOSA will adopt appropriate safeguards to regulate the international data transfers that may take place. Additionally, we inform you that FICOSA may participate in collaboration and research projects together with other entities, in which it will use the personal data identified above. In any case, FICOSA will take the necessary legal measures to regulate data flows, based on a case-by-case analysis, as provided by GDPR. To obtain more information about the recipients of your data, you can contact us by email: dataprotection_spain@ficosa.com.
Data source	We have obtained your personal data through the camera’s devices installed in vehicles that record public roads.
Data subjects’ rights	You may exercise your right of Access, rectification, erasure (“right to be forgotten”), restriction of processing, portability and object by sending a communication to the following email: dataprotection_spain@ficosa.com.
Data subjects’ rights	Data subjects may also have the right to lodge a complaint with the Supervisory Authority (Agencia Española de Protección de Datos: www.aepd.es)

Information regarding the implemented security measures.

Additionally, we inform you that FICOSA is processing your personal data confidentially, keeping the mandatory duty of secrecy. Likewise, technical, and organizational measures have been adopted to guarantee an adequate security level and to prevent its loss, illicit processing and/or unauthorized access.

The aforementioned has been done considering the state of art of the technology, personal data nature and the risks which they are exposed to.

Last updated: November 15^th, 2023