HUAWEI TEST VEHICLE DATA COLLECTION PRIVACY NOTICE

Huawei Technologies Switzerland AG (Huawei, we, us or our) is conducting an automotive sensor research in our office located at Thurgauerstrasse 40, 8050 Zurich, Switzerland. To that end, we have designed a test vehicle that is equipped with various sensors including cameras. It is possible that we capture images and video of you or your vehicle when our test vehicle passes by you in public road. Please be assured that we are not interested in identifying you as an individual. In this privacy notice, we explain what data we collect and operate with our test vehicle.

1. General principles of privacy rights

Huawei has taken comprehensive measures to comply with the Swiss federal act on data protection (FADP), including more general European Global Protection Regulation (GDPR), and to respect the rights of data subjects. When we develop the test vehicle and the data management infrastructure, we uphold the principles of security by design, which guarantee that any personal information is protected at all stages of data collection before our test vehicle hits the road and provide transparency on how it is handled. Huawei has developed policies, procedures, and tools, as well as an extensive training and awareness program for the employees.

Huawei acts as a data controller of personal data for the data collected with our test vehicle. Our data collection activities are limited to Switzerland, and focused in the area of Zurich.

2. What personal data we collect and how we use it

Huawei conducts research in the area of autonomous driving. We collect data in on the public road using our test vehicle. Among these data, the test vehicle will capture images of the surroundings, and record the vehicle's GPS position. We use the collected data to develop algorithms for autonomous driving. These algorithms are used only within a research context. We have no intention to identify any individuals.

Huawei has taken measures to manage the collection, transfer, and use of personal data in a safe manner. These measures include IT infrastructure, data-handling processes and staff training. Wherever possible, we apply data anonymization, i.e., we remove personal information from images and videos by blurring out faces and license plates before analyzing them. We only collect data which is directly required for the research activities listed above. Access to the data is restricted to a small number of people in the Huawei Zurich office.

3. Legal basis for processing your personal data

As described in the previous section, data anonymization is applied to the collected images and videos, wherever possible. Nevertheless, not all the collected data can be anonymized without adversely affecting our research activities. Therefore, we will rely on the legal basis of pursuing our legitimate interests to develop and provide automotive safety products that have world class performance and reliability in real-life driving environments.

4. How long your personal data is stored

We keep the collected data in a secure environment for the time necessary to achieve the purpose for which it was collected but no longer than 3 years from collection date.

5. Your rights in relation to collection of personal data

Our test vehicle is equipped with stickers to notify data subjects that their images might be captured by the test vehicle. The stickers also provide QR code on how to access this privacy notice issued by Huawei, as well as more information about the purpose of the data collection and how the data is processed.

According to GDPR, you as a data subjects have the right to request the following:

• Access to your personal data, in particular, the following information should be available to you upon request:
  a) The purposes for which your personal data is collected
  b) The categories of the personal data
  c) The recipients, or categories of recipients, of the data, if any, in particular any third countries or international organizations
  d) The period of time that the personal data will be stored for (or the criteria used to determine that period)
  e) Whether the personal data is subject to automated processing, including profiling and, if so, the logic and potential consequences involved
  f) Whether the data is transferred to a third country or international organization, information about the safeguards that apply
  g) Information about the source of the data
• Erasure, also known as "the right to be forgotten": you have the right to require Huawei to erase your personal data without undue delay if one of the following applies:
  a) The personal data is no longer necessary for the purpose for which it was collected
  b) You object to the processing of the personal data
  c) The personal data has been unlawfully processed
• Processing restriction: you have the right to restrict the processing of your personal data in one of the following circumstances:
  a) You contest the accuracy of the data
  b) You need the data for legal claims
• Automated decision-making: we do not use automated decision-making and profiling tools, but in the event that this changes, you have the right to not be the subject of automated decision-making where the decision has a significant effect on you, and can insist on human intervention
• The right to lodge a complaint with a data protection regulator: you may file a complaint with the Swiss Fedaral Data Protection and Information Comissioner, at https://www.edoeb.admin.ch/edoeb/de/home/der-edoeb/kontakt/kontaktformular.html

You can exercise the rights above by sending us a request via our Data Subject Rights Portal available at https://www.huawei.com/en/personal-data-request . If you exercise your rights, we will ask you to provide an identity document and check your entitlement to the rights. We might also request additional information in case it is necessary to process your request.

6. Contact us

In case you have any questions or concerns about data protection, your personal data, or if you wish to file a complaint, please contact us via our Data Subject Rights Portal available at https://www.huawei.com/en/personal-data-request

If you have a reason to believe that Huawei breaches your privacy in relation to the automotive data collection in Switzerland or that Huawei does not comply with the data protection measures described in this privacy notice, please contact the Swiss Federal Data Protection and Information Commissioner at https://www.edoeb.admin.ch/edoeb/de/home/der-edoeb/kontakt/kontaktformular.html

7. Update log

This is released version 1.0.