1. Controller and Contact Details of the Data Protection Officer

The controller responsible for data processing is:

Holon GmbH
Elsener Straße 95
33102 Paderborn
Germany
Email: contact@driveholon.com

You can reach the Data Protection Officer of Holon GmbH at the above address with the addition “To the Data Protection Officer” as well as via email at: datenschutz@driveholon.com.

As a rule, the processing of personal data is carried out under joint responsibility pursuant to Art. 26 GDPR together with:

Mobileye Vision Technologies Ltd
Attn: Privacy/Legal Department
Shlomo Momo ha-Levi St 1
Jerusalem, 9777019
Israel
Email: privacy@mobileye.com

For details on the joint controllership, please refer to Section 9.

You can reach the Data Protection Officer of Mobileye Vision Technologies Ltd at the above address with the addition “For the attention of the Data Protection Officer” as well as via email at: privacy@mobileye.com.

2. Purposes and Legal Basis of Processing

The purpose of the processing is to test and further develop the HOLON urban vehicle and its integrated camera technology in road traffic, with regard to traffic safety both inside and outside the HOLON urban. For this purpose, the HOLON urban is equipped with video cameras on the exterior and interior. Additionally, microphones are installed inside the vehicle to detect signals from emergency vehicles.

To ensure safety in and around the HOLON urban, some of the video cameras are operated under the sole responsibility of HOLON GmbH. This includes the interior cameras, one camera at the entry area, and some exterior cameras.

For the testing and improvement of traffic safety, additional exterior cameras are operated under joint responsibility by HOLON GmbH and Mobileye Vision Technologies Ltd. After the video recordings are retrieved from the data loggers in the HOLON urban, they are transmitted by HOLON to Mobileye Vision Technologies Ltd. Both companies process the data jointly in the backend. Additionally, each company also processes data independently for the purpose of testing and developing autonomous driving functions. Further privacy information from Mobileye Vision Technologies Ltd can be found here.

The processing is based on legitimate interest pursuant to Art. 6(1)(f) GDPR.

The legitimate interest lies in testing the safe operation of the HOLON urban in public traffic and in developing self-driving systems. This development requires incorporating real traffic situations to ensure the vehicle can respond appropriately. This includes recognizing human road users, particularly certain external features (e.g., facial characteristics). To achieve the highest possible recognition rate, anonymizing individuals in the video footage (e.g., by pixelation) is not feasible. Inadequate recognition could result in the HOLON urban failing to respond appropriately in certain traffic situations.

However, the recorded video and audio data will under no circumstances be used to identify individual persons or vehicles. Identification is not necessary for the purposes described.

3. Categories of Personal Data

Video recordings are processed of individuals outside the HOLON urban vehicle. In addition to natural persons in public traffic areas, vehicle license plates are also processed.

For individuals inside the HOLON urban, both video and audio recordings are processed.

4. Recipients and Categories of Recipients of Personal Data

HOLON GmbH has commissioned the following companies as processors to handle personal data on its behalf and according to its instructions:

Company/Contact: Processing Activity

Companies of the HOLON Group: Corporate services

Companies of the BENTELER Group: Services such as IT operations / communication

Research project partners: Services such as data transfer

Development service providers outside HOLON: Services such as development / analysis

Hosting service providers: Services such as data storage

Mobileye Vision Technologies Ltd has commissioned the following companies as processors to handle personal data on its behalf and according to its instructions:

Company/Contact: Processing Activity

Companies of the Mobileye Group: Corporate services

Development service providers: Services such as development / analysis

Hosting service providers: Services such as data storage

IT service providers: Services such as IT operations / communication

5. Transfer to Third Countries

Mobileye Vision Technologies Ltd, as a joint controller, is headquartered in Israel. With regard to Israel, there is an adequacy decision by the European Commission, confirming that Israel generally provides an adequate level of data protection.

In addition, a contract based on the EU Standard Contractual Clauses has been concluded between HOLON GmbH and Mobileye Vision Technologies Ltd. These clauses can be accessed here.

6. Storage Duration

The data is processed for the duration of the testing and further development of the HOLON urban vehicle. As soon as the data is no longer required for the aforementioned purposes, it will be promptly deleted.

7. Source of Data Processing

The data is collected through video recordings of individuals outside the HOLON urban vehicle who are present in public areas and within the range of the video cameras. For individuals inside the HOLON urban, personal data is processed via both video and audio recordings.

8. Data Subject Rights

As with any processing of personal data, you are entitled—provided the legal requirements are met—to the following rights:

- The right of access to personal data concerning you

- The right to rectification, erasure, or restriction of processing

- The right to data portability

- The right to withdraw consent at any time with effect for the future

- The right to object to the processing of your data

- The right to lodge a complaint with a supervisory authority regarding the processing

All data subject requests are reviewed on a case-by-case basis. For technical reasons, deletion of video or audio recordings cannot be carried out directly within the HOLON urban vehicle.

9. Information Pursuant to Article 26(2) GDPR

HOLON GmbH and Mobileye Vision Technologies Ltd (hereinafter jointly referred to as the “Parties”) process personal data as joint controllers under Article 26 GDPR for certain processing activities. The Parties have jointly defined the processing of personal data in specific process stages and are therefore jointly responsible for the processing within the following stages:

- Creation of video and audio recordings for testing and further development of autonomous driving functions

- Extraction of recordings from the data loggers

- Transmission of the recordings to Mobileye Vision Technologies Ltd

- Processing of the transmitted recordings in the Mobileye backend

In contrast, the further processing of video recordings for the purpose of testing and developing the digital driver is carried out solely by Mobileye Vision Technologies Ltd. Information on the processing of personal data under the sole responsibility of Mobileye Vision Technologies Ltd can be found on their privacy page.

For the jointly controlled processing stages, the Parties have contractually agreed on the following:

- HOLON GmbH provides data subjects with the information required under Articles 13 and 14 GDPR. The necessary content is coordinated between the Parties.

- The Parties inform each other of any data subject rights exercised. They will promptly share the necessary information with one another.

- Data subjects may exercise their rights with either HOLON GmbH or Mobileye Vision Technologies Ltd.