LiangDao
|

Data Protection Policy

Last updated: 24.06.2026 | Version: 2.0

At LiangDao GmbH, protecting your personal data is a core responsibility. This policy explains who we are, what personal data we collect about you, how we use it, and what rights you have. It covers our company's data processing activities — including our website, our business relationships, and our ADAS data collection programme operating on public roads within the EU, EEA, and United Kingdom.

We process personal data in compliance with the EU General Data Protection Regulation (GDPR), the Bundesdatenschutzgesetz (BDSG), and other applicable national data protection laws.

1. Who We Are

LiangDao GmbH is the data controller responsible for the processing of personal data described in this policy.

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

1.1 Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is your primary contact for all data protection matters. You can reach our DPO at:

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

You can contact the DPO at any time to exercise your data subject rights, ask questions about this policy, or raise concerns about how we handle your personal data.

2. What Personal Data We Collect and Why

We interact with different groups of people in different ways. The personal data we collect, and the reasons we collect it, depend on how you come into contact with us. We describe each context below.

🌐 Website visitors
When you visit our website, our server automatically records: your internet service provider's name; the website from which you visited us; the pages on our site you visit; and the date and duration of your visit. This information is used for technical administration and security purposes only. We use browser localStorage solely to remember your language preference (English or German) between visits. This website does not use cookies or tracking technologies.
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) — technical administration and security of our website.

💼 Job applicants
If you apply for a position with us, we process the personal data you provide in your application — CV, cover letter, qualifications, references — for the purpose of assessing your suitability for the role.
Legal basis: Pre-contractual measures (Art. 6(1)(b) GDPR) and legitimate interests (Art. 6(1)(f) GDPR).

🚗 Road users — ADAS data collection on public roads
If you were present on a public road in the EU, EEA, or United Kingdom when one of our data collection vehicles passed, our vehicle cameras may have captured footage including your image, your vehicle's licence plate, and GPS location and timestamp data. We process this data for AD (Autonomous Driving) and ADAS (Advanced Driver Assistance Systems) research and development — specifically for training and validating perception algorithms in our current certified processing stage. Face and licence plate blurring is applied after footage is transferred to our central processing environment. The processed dataset retains GPS/geolocation coordinates and remains personal data — it is de-identified, not anonymized. Your data subject rights continue to apply.
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) — development and validation of safe automated driving systems for road safety improvement. To the extent that recordings incidentally capture data that may fall within Article 9 GDPR (e.g. visible facial features or other sensitive physical characteristics), this capture is not intentional and no identification or profiling is performed. The applicable legal basis for any such incidental capture is Art. 9(2)(g) GDPR (substantial public interest in road safety) in conjunction with §22(1) No. 2 BDSG, with specific safeguards applied. For the full Art. 14 GDPR privacy notice, see Section 8.

3. Who We Share Your Data With

We do not sell personal data to third parties. We share personal data only where necessary and under strict contractual protections:

4. International Data Transfers

We are based in the EU and primarily process personal data within the EU/EEA. Where we engage service providers located outside the EU/EEA, we ensure appropriate safeguards are in place under Art. 46 GDPR — such as Standard Contractual Clauses (SCCs) adopted by the European Commission, or an adequacy decision covering the recipient country.

Personal data collected through our ADAS programme is stored and processed in Germany (EU), using cloud infrastructure in the AWS Europe (Frankfurt) Region. No ADAS data is transferred outside the EU/EEA or United Kingdom.

5. How Long We Keep Your Data

We retain personal data only for as long as necessary for the purpose for which it was collected. Our general retention periods are:

Website server logs
7 days — for security and technical administration purposes
Business contact data
36 months after the end of the business relationship, or last contact
Job application data
6 months after the close of the recruitment process, unless you consent to longer retention
ADAS raw video data
Deleted within 14 days of successful blurring, max. 30 days from ingestion/receipt
ADAS de-identified dataset (GPS/geolocation retained — data subject rights continue to apply)
Up to 5 years from ingestion/receipt, or 3 years after project closure, whichever is earlier
Fully anonymized ADAS output (GPS also removed)
Up to 10 years from anonymization — once GPS has also been removed, this data cannot be linked to any individual and data subject rights no longer apply
Legal / compliance records
As required by applicable law (typically 3–10 years)

6. Your Rights

As a data subject under the GDPR, you have the following rights. We will respond to any request within one month of receipt. To exercise any right, contact our DPO using the details in Section 1.

AccessYou can ask us to confirm whether we hold data about you and request a copy of it.
RectificationYou can ask us to correct inaccurate or incomplete data about you.
ErasureYou can ask us to delete your data where we no longer have a valid reason to hold it.
RestrictionYou can ask us to pause processing of your data in certain circumstances.
ObjectionYou can object to processing based on our legitimate interests. We will cease unless we have compelling grounds that override your interests.
PortabilityWhere processing is based on consent or contract, you can ask for your data in a structured, machine-readable format.
Withdraw consentWhere processing is based on consent, you can withdraw it at any time without affecting prior processing.
No automated decisions (Art. 22)You have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects. LiangDao GmbH does not carry out automated individual decision-making of this kind — this right is not applicable to our current data processing.

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.

You also have the right to lodge a complaint with the supervisory authority if you believe our processing of your personal data does not comply with the GDPR:
Berliner Beauftragte für Datenschutz und Informationsfreiheit (BlnBDI)
Alt-Moabit 59–61, 10555 Berlin
https://www.datenschutz-berlin.de | mailbox@datenschutz-berlin.de

7. Cookies and Browser Storage

This website does not use cookies of any kind — no analytics, no advertising, no session cookies, no third-party cookies. We use browser localStorage solely to remember your language preference (English or German) between visits. localStorage is browser-side storage — it is not transmitted to our servers, is not accessible to third parties, and does not require consent under the ePrivacy Directive or TDDDG §25. To clear your language preference, you can clear your browser's site data at any time in your browser settings.

For full details on how we use browser storage and how to clear your preferences, see our Cookie and Browser Storage Policy.

8. ADAS/AD Data Collection — Specific Notice

If you have seen one of our data collection vehicles on the road, a dedicated privacy notice for this processing activity is available by scanning the QR code on the vehicle, or via our ADAS/AD Data Collection Notice. That notice contains the full information required by Article 14 GDPR for data subjects whose data is incidentally captured during our ADAS research and development activities.

9. Changes to This Policy

We review and update this policy periodically to reflect changes in our processing activities, our organisation, or applicable law. The date of the most recent update is shown at the top of this page. We recommend checking this page periodically. For material changes that affect your rights, we will notify you through our website or by direct communication where appropriate.