Privacy Policy for the Development of ADAS
This privacy policy explains how SEAT, S.A. processes and uses your personal data to develop and enhance driver assistance and automated driving functions, as well as to provide additional services aimed at improving overall road safety. SEAT, S.A. is a Spanish manufacturer of certified commercial vehicles, operating under the SEAT and CUPRA trademarks. Hereinafter, SEAT, S.A. may be referred to as SEAT or CUPRA indistinctly.
1. Who is the Data Controller?
- SEAT, S.A.U. with NIF A-28049161 (SEAT / CUPRA)
- Address: Autovía A-2, Km. 585, Martorell (Barcelona, Spain)
- Contact: customercare@cupraofficial.com
2. What type of data do we process and what is its origin?
Our vehicles are equipped with cameras and sensors outside the vehicle, capable of collecting certain data and information from public roads in certain circumstances:
- Video and film recordings
- Image and photo recordings
- Audio recordings
- Location data: stationary location data (GPS position and the timestamp.)
Note that the identification of individual persons is not intended at any time and is not required for the purposes listed below. Persons, vehicles and other objects are only considered as “objects” in the context of traffic and environmental situations, e.g., “pedestrian at the right‑hand roadside”. Without your active contribution and provision of further data, we will not be able to attribute the data collected to a natural person.
3. For what purpose do we process your data and what is the legal basis?
The main purpose of data recording and processing is to develop and improve driver assistance and automated driving functions (ADAS functions, necessary for the approval of future vehicles, as well as those services and functions related to the vehicle, which may be suitable to increase general road safety. Data recording and processing take place in predefined traffic scenarios through events or campaigns specifically designed for this purpose, using sensors and image-capture technology. These “events” or traffic situations may involve safety-critical scenarios, such as emergency braking, or local conditions, such as poorly marked lanes or unusual traffic signs. Identifying critical road safety situations, along with developing and optimizing related systems and functions, is essential to the ongoing improvement of our vehicles’ driver assistance systems.
This data processing may involve individuals who are near the vehicle or directly engaged in a traffic situation that is critical to the safety of people. In such cases, our vehicles may capture an image of an individual at a specific moment. Nevertheless, we inform you that any images and data collected are anonymized through a pixelation process within a maximum of 48 hours. From this point on, any people, vehicles, or other objects in the surrounding area are treated as ‘anonymous objects’ within the context of traffic, such as ‘pedestrians on the right side of the road.’ We process this information solely to improve the software and ensure that any personal characteristics not essential to the development of the driving and road safety system are excluded, in compliance with applicable data protection regulations.
We will process your personal data in full compliance with the General Data Protection Regulation (GDPR) and other applicable data protection laws. Specifically, the purposes and legal bases for the processing of your data are as follows:
Purpose | Data | Legal basis | Examples |
Data collection for the development of driver assistance and automated driving functions and services | Recordings (video/film, image/photo, audio), location data (stationary location data) | Art. 6(1)(f) GDPR – legitimate interests of SEAT/the third party on developing, testing, validation and release of safety relevant driver assistance systems for active and passive safety up to automated and autonomous driving systems that can improve overall road safety.
| Extracting recordings from the vehicle environment only in narrowly defined safety-critical situations (such as emergency braking or sudden evasive manoeuvres) for the sole purpose of developing and validating driver assistance and automated driving functions and services, thereby enhancing product integrity, vehicle performance, and overall road safety. |
Evaluation of recordings captured from real traffic situations | Recordings (video/film, image/photo, audio), location data (stationary location data) | Art. 6(1)(f) GDPR – processing based on legitimate interests to detect the vehicle environment, identify obstacles and road conditions, and recognise traffic participants, including their movement patterns, in order to determine the appropriate vehicle response. | Assessment of recordings from the vehicle environment, including the collection, processing, and secure storage of video, audio, and image data, for the purpose of enhancing driver assistance and information systems by improving the recognition of road users, traffic situations, and other relevant objects. |
Safeguarding and defending our rights and disclosure in the context of governmental/judicial measures | Recordings; location data | Art. 6(1)(c) GDPR - legal obligation under EU/member state law. Art. 6(1)(f) GDPR – legitimate interests of SEAT/the third party.
| Exercising and asserting rights and claims; disclosure for evidence collection; criminal prosecution and enforcement of civil claims |
Compliance with legal requirements / processing based on legal provisions | Recordings; location data | Art. 6(1)(c) GDPR - legal obligation under EU/member state law. | Handling data subject requests under the GDPR; handling reports of potential personal data breaches |
4. How is your data protected, and what are the retention periods?
Pixelated images will be retained for up to one year for the purposes outlined above, unless a longer retention period is required to comply with legal obligations. Extended retention may be required for quality assurance and error resolution Data will be deleted as soon as the purpose for which it was collected and processed no longer applies, and at the latest within the legally required timeframe.
5. Who are the recipients of your data?
In general, we inform you that we will not disclose your personal data to third parties except when required to comply with a legal obligation or in the specific cases detailed below:
As certified vehicle manufacturers, we are obliged, upon request from the competent authorities, to process and share certain data stored in your vehicle. Some of these obligations may arise from the investigation of criminal offenses, traffic accidents, second-hand sales control, and similar circumstances. Any disclosure of data to the authorities will always be covered by compliance with the corresponding applicable legal obligations (Art. 6.1(c) GDPR).
Furthermore, our company is part of the Volkswagen Group. In this regard, we inform you that we use data servers, IT service providers, and other suppliers and third parties contracted by the Volkswagen Group, which also provide maintenance and technical support for the IT systems in our vehicles. These third parties, as well as SEAT and Volkswagen suppliers, will always process personal data on our behalf and in accordance with our instructions.
Finally, under certain circumstances, SEAT may share your data with companies within the Volkswagen Group for the purpose of improving and innovating products related to your vehicle’s safety. These companies are: Volkswagen AG, Škoda Auto a.s., and Cariad SE.
6. Will your data be transferred outside the European Economic Area?
As a rule, your data will be processed within the EEA (European Economic Area), to which the GDPR applies without restriction. However, as a globally active company, we may, in exceptional cases, need to store and process data outside the EU. Please note that we will only transfer your personal data to third countries when permitted under the GDPR. Unless an adequacy decision has been made by the European Commission, we will only transfer your data to third countries if this is permissible under Art. 44 – 49 GDPR. To the extent that SEAT S.A. relies on appropriate safeguards in accordance with Article 46 para. 2 GDPR for the transfer to third countries (e.g. standard contractual clauses or binding corporate rules), we will take additional technical and/or organizational measures if this is necessary to maintain adequate protection of your data. The agreements with processors regularly provide for the conclusion of standard contractual clauses of the European Commission to ensure an adequate level of data protection.
7. What are your rights as a data subject?
Your rights as a data subject are set out below:
Right | Content |
Access | You have the right to request confirmation of whether we process your personal data and to access the personal data contained in our records |
Rectification | You have the right to correct inaccurate personal data and to complete any incomplete information. |
Suppression | You may request the erasure of your personal data when, among other reasons, it is no longer necessary for the purposes for which it was collected |
Opposition | You have the right to request that your personal data not be processed. Our organization will cease processing your data, except where there are compelling legitimate grounds or for the establishment, exercise, or defense of legal claims |
Limitation | You may request the restriction of processing of your personal data in the following circumstances: • While the accuracy of your data is being challenged; • When the processing is unlawful, you object to the deletion of your data, and request the limitation of its use; • When we do not need to process your data, but you need it for the exercise or defence of claims; • When you have objected to the processing of your data for the fulfilment of a mission in the public interest or for the satisfaction of a legitimate interest, while it is verified whether the legitimate grounds for the processing override yours. |
Portability | You may receive, in electronic form, the personal data you have provided to us and those obtained from your contractual relationship with us, as well as transmit them to another entity. |
8. How can you exercise your rights?
You can exercise these rights by submitting a written request to SEAT, S.A Autovía A-2 Km. 585, Martorell (Barcelona), Spain, or to the email address customercare@cupraofficial.com. The exercise of these rights is free of charge except in the case of manifestly unfounded or excessive requests. In the event that there is reasonable doubt about your identity, you may be asked for additional information necessary for us to confirm it and thus be able to respond to your right. In the event that you consider that we have not processed your personal data in accordance with the applicable regulations, you may file a complaint with the Spanish Data Protection Agency through the website www.aepd.es. or competent supervisory authority.
9. Data Protection Officer
If you have any questions about data protection or wish to contact our Data Protection Officer ("DPO"), you can contact them by emailing them at dataprotection@seat.es
Last update: November 2025
