LiangDao
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Privacy Notice — ADAS/AD Data Collection

Last updated: 15.06.2026

If you have seen one of our data collection vehicles on the road, this notice explains what personal data our vehicle cameras may have captured, why we process it, and what rights you have.

We are committed to handling your personal data responsibly and in full compliance with the EU General Data Protection Regulation (GDPR). We do not seek to identify you as an individual — our systems are designed and configured for that specific purpose, and your identity is not relevant to our work.

1. Who Is Responsible for Processing Your Data?

The data controller responsible for the processing described in this notice is:

CompanyLiangDao GmbH
AddressPlinganserstraße 134, 81369 München
Websitewww.liangdao.de
Emailinfo@liangdao.de
RegisteredMunich (Amtsgericht München); HRB 242626

Data Protection Officer (DPO)

DPO NameQing Yang
DPO Emaildpo@liangdao.de
DPO AddressLiangDao GmbH T.E. Berlin Zweigniederlassung, Pascalstr. 10, 10587 Berlin
DPO Phone+49 (0)15224573930

Contact for data subject requests

For any questions about this notice or to exercise your rights, please contact us at: dpo@liangdao.de.

2. What Personal Data Do We Collect, and Why?

Our vehicles are equipped with externally mounted cameras that record the surrounding road environment while driving on public roads within the EU, EEA, and United Kingdom. The purpose of this data collection is to develop, test, and validate Advanced Driver Assistance Systems and Automated Driving (ADAS/AD) systems — specifically to train and improve algorithms for functions such as lane topology detection, road sign detection, vehicle control, and driving decision-making.

We do not collect data to identify individual people. Our systems are not designed or configured for that purpose. Personal data is captured only incidentally — as a by-product of recording the road environment.

Categories of personal data that may be captured:

A note on sensitive personal data:

Camera recordings in public environments may incidentally capture characteristics that fall within special categories of personal data under Article 9 GDPR — for example, visible health conditions, disability, or other physical characteristics. We do not intend to process such data and take active steps to prevent it: identifiable elements including faces and licence plates are automatically detected and blurred as part of our data processing pipeline. We do not use any captured data to make inferences about individuals' sensitive characteristics. To the extent that any such incidental capture constitutes processing of special category data, the legal basis is Article 9(2)(g) GDPR (substantial public interest) in conjunction with §22(1) No. 2 BDSG (German national implementing provision for substantial public interest processing), applied solely for the period between initial capture and completion of the anonymization process.

Scope of this notice:

This notice covers data collected by our ADAS data collection vehicles operating on public roads within the EU, EEA, and United Kingdom. It does not cover data collected through our general website or other services. Perception processing is not part of the current certified data collection scope.

Why we have not notified you individually:

Because data collection takes place in public spaces involving very large numbers of people, it is not practicable to identify and individually notify every person who may appear in our footage. Individual notification would be impossible or would involve a disproportionate effort within the meaning of Article 14(5)(b) GDPR.

To protect your rights in the absence of individual notification, we have put in place the following compensating measures:

3. What Is Our Legal Basis for Processing?

We process your personal data on the basis of our legitimate interests under Article 6(1)(f) GDPR. Our legitimate interest is the development and validation of safe automated driving systems, which contributes to road safety and the reduction of traffic accidents.

We have carefully assessed whether this interest overrides your rights and interests as a data subject. We have concluded that it does, for the following reasons:

You have the right to object to processing based on legitimate interests at any time. See Section 6 for details.

4. How Do We Protect Your Privacy?

Privacy protection is built into our data collection process from the start. The following measures are applied:

Automated anonymization

Faces and vehicle licence plates are automatically detected and blurred as a post-collection processing step. Raw footage is transferred from the vehicle to our central processing environment before blurring is applied. The blurring process uses advanced detection algorithms, achieving a detection recall of over 95% for clearly visible faces and licence plates with a false-negative rate of below 5% for clearly identifiable objects. Raw footage containing unblurred identifiable elements is deleted within 14 days of successful blurring, and in any case within 30 days of ingestion into the central processing environment.

Data minimisation

We collect only the data necessary for the development of automated driving functions. We do not collect audio, interior vehicle data, or any data beyond what is captured by the externally mounted cameras within the scope of this project.

Access controls

Access to collected data is strictly limited to authorised personnel involved in ADAS research and development. All data is stored securely with appropriate technical and organisational measures in place.

Limited retention

We retain personal data only for as long as necessary for the research and development purpose. Raw data is deleted within 14 days of successful blurring, and in any case within 30 days of ingestion into the central processing environment. De-identified data is retained for the duration of the relevant R&D project, not exceeding 5 years from data ingestion / receipt, or 3 years after project closure, whichever is earlier.

5. Who Receives Your Personal Data?

We share personal data only where necessary and under strict contractual protections. Recipients include:

Within our organisation

De-identified data is shared with our internal ADAS research and development teams for algorithm training and validation purposes. Access is role-based and limited to authorised personnel.

Service providers (data processors)

We engage third-party service providers to support our data collection and processing activities. These include providers of cloud infrastructure and storage. All processors are bound by data processing agreements in accordance with Article 28 GDPR and may only process data on our documented instructions.

Customers

Following face and licence plate blurring, processed data may be transferred to our customers within the European Union for validation and testing purposes. The transferred dataset is processed / de-identified personal data: facial and licence plate identifiers have been blurred, but GPS/geolocation data is retained. The transfer is made under an Art. 28 GDPR Data Processing Agreement with each customer, who is contractually restricted to using the data only for the agreed purposes.

Legal disclosures

We may disclose personal data to law enforcement authorities, regulators, or other third parties where required by law or where reasonably necessary to protect the security or integrity of our systems or to comply with legal obligations.

6. Where Is Your Data Stored and Processed?

Your personal data is stored and processed within the European Union / European Economic Area. Data collected on vehicles is stored on encrypted physical hard drives before transfer to our processing environment in Berlin, Germany. Where cloud infrastructure is used, storage and processing uses the AWS Europe (Frankfurt) Region, Germany. No data is stored or processed outside the EU/EEA.

We do not transfer personal data to countries outside the EU/EEA in connection with this data collection activity. De-identified data transferred to customers remains within the EU/EEA.

7. How Long Do We Keep Your Data?

We retain personal data only for as long as necessary to fulfil the purposes described in this notice:

8. Your Rights

As a data subject under the GDPR, you have the following rights in relation to your personal data. We will respond to any request within one month of receipt.

Right of access (Art. 15)

You have the right to obtain confirmation of whether we are processing personal data about you and, if so, to receive a copy of that data and information about how it is processed.

Right to erasure (Art. 17)

You have the right to request that we erase your personal data where continued processing is not justified.

Right to restriction (Art. 18)

You have the right to request that we restrict the processing of your personal data in certain circumstances, for example where you contest its accuracy.

Right to object (Art. 21)

You have the right to object to the processing of your personal data on the basis of our legitimate interests. If you object, we will cease processing unless we can demonstrate compelling legitimate grounds that override your rights and interests. To exercise this right, please contact us using the details in Section 1.

Right to data portability (Art. 20)

The right to data portability applies only where processing is based on consent or a contract (Art. 20(1) GDPR). As our processing is based on legitimate interests under Article 6(1)(f) GDPR, this right is not applicable to the data collection activities described in this notice.

Right to rectification (Art. 16)

You have the right to request correction of any inaccurate personal data we hold about you.

No automated individual decision-making (Art. 22)

LiangDao GmbH does not carry out automated individual decision-making that produces legal or similarly significant effects within the meaning of Article 22 GDPR. This right is therefore not applicable to our current processing activities.

Please note that the exercise of your data subject rights in relation to ADAS data collection may be limited in practice. As we do not actively collect or index personal data by individual, there is no automated mechanism to search our datasets by individual identity or vehicle. To help us investigate your request manually, please provide as much additional information as possible, such as the approximate location and time of the recording, your vehicle's licence plate, and your role in traffic at the time of capture.

To exercise any of these rights, please contact us at the details provided in Section 1. We may need to verify your identity before processing your request.

9. Right to Lodge a Complaint

If you believe that our processing of your personal data does not comply with the GDPR, you have the right to lodge a complaint with the competent data protection supervisory authority. The lead supervisory authority responsible for our processing activities is:

Berliner Beauftragte für Datenschutz und Informationsfreiheit (BlnBDI)
Alt-Moabit 59–61, 10555 Berlin
https://www.datenschutz-berlin.de | mailbox@datenschutz-berlin.de | +49 30 13889-0

You may also find your national supervisory authority through the European Data Protection Board (EDPB) at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

Note: if our data collection vehicles operate in EU member states other than Germany, or in Norway or the United Kingdom, data subjects in those jurisdictions retain the right to lodge a complaint with their own national supervisory authority — under Article 77 GDPR for EU/EEA, and under the UK GDPR for UK data subjects. The data protection authorities of additional collection jurisdictions can be provided upon request. Contact us at the address in Section 1 if you require assistance identifying the relevant authority.

10. Changes to This Notice

We review this Privacy Notice periodically and update it where necessary to reflect changes in our processing activities or applicable law. The date of the most recent update is shown at the top of this notice. We recommend that you review this page periodically.