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Privacy Notice on Data Collection Activities for the “VISION-S” Project

Sony Corporation ("we") collect certain data as stated below on public roads as part of our "VISION-S" project. This notice describes what and how we collect and handle such collected data, how you can contact us. We may revise this privacy notice by posting the new privacy notice here.

1. Categories of Collected Data

We take images and videos of persons/objects on public roads (for more details, please see Recording Schedule and Location below through outward cameras of our (or our project partners') vehicles.
Although these data may contain persons' faces and license plates, etc. involved in road traffic, we ensure they will be used only for the purposes stated below and not used for identifying individual persons or any other purposes.

2. Purpose of Processing

We will use the collected data for our vehicle's sensor tuning, evaluation and verification of our vehicles (e.g. their Advanced Driver Assistance Systems' functionality), and future mobility/robotics-related development, in pursuit of our legitimate interest.

3. Sharing of Collected Data

3-1. Sony Affiliates
The collected data may be shared with and used by our affiliates to pursue the activities related to the purposes above.
3-2. Service Providers and Project Partners
We and our affiliates may engage third-party service providers or project partners, with whom we enter into agreements as required under applicable law, to process the collected data on our behalf for the purposes above.
3-3. Others
In the event that we or our affiliates sell or transfer a portion or all of its business, the collected data may be transferred to the purchasing or acquiring entity as part of the transaction.
We and our affiliates may disclose any of the collected data if required or permitted by applicable law, or if we believe in good faith that disclosure is reasonably necessary for us to protect or enforce the rights, property, safety or security of ourselves or others, to third parties including government authorities and law enforcement officials, and auditors and similar external consultants like lawyers and tax advisors.

4. Retention Period

Until the above purposes of processing are achieved and there is no longer a need to use the data. However, the collected data will be deleted after 3 years from the date of acquisition.

5. Transfer of Collected Data Internationally

The collected data may be transferred in harmony with Section 2 and Section 4 to countries/regions outside your country/region of residence, including in particular Japan and the United States of America, in which the privacy laws may not be as comprehensive as those in your home country/region.

Where information is transferred out of the EU/EEA, we will, to the extent that no statutory level of data protection comparable to the European data protection laws exists in such countries, adopt appropriate measures to ensure that the collected data about you will be adequately protected in those countries. In particular, we may apply the standard contractual clauses published by the European Commission. Where the collected data is transferred to Japan, the adequate level of data protection is confirmed by the European Commission's adequacy decision.

6. Your Rights

You can request access to, and amendment/deletion of, the collected data we hold about you. However, we may decline to process requests which are extremely unreasonable/impractical or not required by law.

If you are located in the EU/EEA, you may have the following rights under certain conditions of the European data protection laws with regard to the collected data about you:
- You have the right to access (including a copy of) the collected data about you; to correct, delete or restrict (stop any active) processing of the collected data about you.
- In addition, you can object to the processing of the collected data about you in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

You also have the right to complain to a supervisory authority for data protection in the country/region where you live, where you work, or where you consider that a breach of data protection has occurred - although we hope that we can assist with queries or concerns you may have regarding our use of the collected data about you.

7. Contact Information

Sony Corporation, a Japanese company, having its principal office at 7-1 Konan 1-chome, Minato-ku, Tokyo 108-0075, Japan, is the controller for the collected data.

If you are in the EU/EEA: Our representative in the EU/EEA is Sony Europe BV, a Dutch company, whose business address is Taurusavenue 16, 2132LS Hoofddorp, the Netherlands. You can contact our representative in the EU/EEA by emailing: privacyoffice.SEU@sony.com. You can also get in touch by writing to Sony Europe BV at the address above or at The Privacy Office c/o Sony Europe Legal Department, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, The United Kingdom, or you can contact your local Sony company at http://sony-europe.com.

Effective Date: This privacy notice is effective as of October 13, 2020 .

Recording Schedule and Location

Date Location Itinerary
Oct. 1-Nov. 30, 2020 Hungary M0, M1, M3, M31, M5, M6, M7, road 11 & roads in the 2nd and 3rd districts of Budapest
Oct. 1-Nov. 30, 2020 Austria A2, A9 & S35
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