Privacy Policy

Effective from 24th August 2020

Review and approval history: 24th August 2021, 22nd August 2022, 27th September 2023.

This Privacy Policy explains how information about you is collected, used and disclosed by Limited. This Privacy Policy applies to information we collect when you use our websites and other products and services that link to this Privacy Policy (collectively, the “Services”). We may supply a different privacy policy in relation to some of our Services, and that policy will apply to any information provided to or collected by us connected to those specific services.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

Information you provide to us

We collect information you provide directly to us. For example, we collect information when you participate in any interactive features of the Services, fill out a form, provide feedback, participate in a contest or promotion, apply for a job, communicate with us via third party sites, request customer support, or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, phone number, and any other information you choose to provide.

Information collected when you access or use our services

When you access or use our Services, we may automatically collect information about you, including:

  • Log information: We may collect log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
  • Information collected by cookies: Like many websites, we may use cookies to collect information about visitors and visits to our Site. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. For more information about cookies, and how to disable them, please see “Your Choices” below.

Information we collect in order to maintain and improve our business offering

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The data we collect, use and store takes the form of visual images and footage captured on and around roads from moving or static cameras or other sensors. We will not actively seek to identify you and we will not use the data to monitor or track the movements or activities of individuals for extended periods. However, individuals may be identifiable in the data we collect by, for example, their physical appearance, location, who they are with or any identifier relating to them (e.g: a car number plate).

We will not intentionally collect any Special Categories of Personal Data (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data). However, we acknowledge that certain aspects of your appearance or activities reflected in the data we collect may fall into these Special Categories of Personal Data. As the data we collect only relates to what is visible from a car on a road or from pavements and other public spaces alongside roads, we would only expect this to relate to information about you that you are comfortable allowing to be visible in public areas. We do not intentionally collect any information about criminal convictions and offences (we would only collect this type of data if it happened to be visible in the data we collect).

We may automatically collect information about you, via:

  • The recording and collection of normal driving behavior in order to collect accident or near miss scenario data. We will collect data from cameras and other sensors being operated by personnel at head height or pole elevation on pavements and other public spaces alongside roads within the UK, and occasionally at higher elevations (e.g. from buildings).
  • Third parties or publicly available sources. In addition to collecting data ourselves, we may also receive footage from third party partners. As we are not involved in the collection of this data and we do not attempt to systematically identify individuals within either the data we collect or the data we receive, we are not able to notify you individually if we receive personal data relating to you. However, in the interests of transparency, we wanted to bring this fact to your attention and to assure you that we consider and balance the interests of individuals whose personal data is contained in any data we receive from third parties in the same way as for data we collect ourselves.

 Information we collect from other sources

We may also obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you from third parties, including but not limited to identity verification services and publicly available sources.

We will only use your personal data when the law allows us to. Generally, this will only be where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

The legitimate interests we rely on as the legal basis of our use of your personal data are the interests of our business and of society more generally in testing, developing and using autonomous vehicle test products. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Otherwise, we will only use your personal data where it is necessary for us to comply with legal or regulatory obligations that we are subject to.

While you may have a right to object to our use of your personal data, we do not rely on consent as a legal basis for processing your personal data.

Purposes for which we will use your personal data

Below, we have set out a description of the ways we plan to use any personal data we collect, and what lawful basis we rely on to do so.

Primary product – Edge case scenario testing for Autonomous Vehicles:

  • Purposes/Activities: To develop test software for the testing and training of autonomous vehicles, such as software that allows an Autonomous vehicle controller to be tested in a variety of test scenarios (based on data taken from the real world) in the simulation domain.
  • To develop virtual simulation environments for use in developing autonomous vehicle test software.
  • Type of data: Visual footage of road or street scenes (including pedestrian behaviour) and traffic situations.
  • Lawful basis for processing: Necessary for our legitimate interests (developing and verifying autonomous vehicle test systems).

Supplementary product – Real Time monitoring of social distancing:

  • Purpose/Activity: To assess the effects of the UK government social distancing guidance within towns and cities.
  • To assist with COVID-19 social distancing campaign. Provide advice to Public Health England and Local Authorities.
  • Type of data: Visual footage of road or street scenes (including pedestrian behavior) and traffic situations.
  • Lawful basis for processing: To assist the UK government and local authorities to understand the impact and success of the social distancing guidance.
  • Providing an evidence based understanding of social distancing bottle necks and problem areas on footpaths and crossings allowing local authorities to take a course of action.

We may use information about you for various purposes, including to:

 Provide, maintain and improve our Services;

  • Provide and deliver the products and services you request, and send you related information;
  • Respond to your comments, questions, and requests and provide customer service;
  • Communicate with you about products, services, offers, promotions, rewards, and events offered by and others, and provide news and information we think will be of interest to you;
  • Monitor and analyse trends, usage, and activities in connection with our Services;
  • Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of and others;
  • Personalise and improve the Services and provide advertisements, content, or features that match user profiles or interests;
  • Link or combine with information we get from others to help understand your needs and provide you with better service; and
  • Carry out any other purpose described to you at the time the information was collected.

Sharing of information

We may share information about you as follows or as otherwise described in this Privacy Policy:

  • With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
  • If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
  • Between and among and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
  • With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

 Social media sharing features

The Services may offer social sharing features and other integrated tools, which let you share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Advertising and analytics services provided by others

We may allow others to provide analytics services and serve advertisements on our behalf across the Internet and in applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by and others to, among other things, analyse and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioural advertising purposes, please visit

Security takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction.

Transfer of data

Whenever we transfer your personal data out of the European Economic Area (EEA), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Your choices


Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Promotional communication

You may opt out of receiving promotional messages from by following the instructions in those messages. If you opt out, we may still send you non-promotional emails, such as those about our ongoing business relations.

Contacting us

If you have any questions about this Privacy Policy, please contact us at or via our postal address: Limited, 136 High Holborn, London, WC1A 6PX.


You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance..