Our commitment to privacy
The partners of the LuxTurrim5G Ecosystem (the “Partners”, “we”, “us”, “our”) are piloting and testing a number of public safety, traffic, logistics, air quality, smart energy and other smart city solutions for City of Espoo and other ecosystem partners.
We are committed to respecting your privacy and to complying with applicable data privacy laws. This privacy notice (“Privacy Notice”) describes how we collect and use personal data where one or more of the Partners is a controller of your Personal Data. “Personal data” means information about you or another identifiable individual.
We promise:
We will not sell, rent or lease your Personal Data
We will keep your data safe and private
We will support your rights as described below in this Privacy Notice
We may change this Privacy Notice from time to time and, where we make any material changes, we will seek to inform you of these. A copy of this Privacy Notice can be found at: www.luxturrim5g.com/privacy
What Personal Data do we collect and what do we use it for?
General overview
As part of the LuxTurrim5G Ecosystem we are collecting and using certain Personal Data to pilot and test a number of solutions to create the digital backbone for a smart city. The Personal Data we use will relate primarily to members of piloting and testing team and aim is to limit the need to collect data from the members of the public. The Personal Data may include (i) video images, audio recordings and vehicle registration information collected by using the cameras and audio sensors on smart poles, drones and information displays in the Nokia Espoo Campus and surrounding areas; and (ii) location data, health data and basic personal information such as names, contact numbers and email addresses that you provide, or is other collected, when you interact with our apps or services used as part of the LuxTurrim5G Ecosystem.
We intend to pilot and test a number of different smart city solutions that may involving the processing of Personal Data including, among other things (i) smart transport solutions, such as autonomous vehicles (ii) smart traffic solutions for pedestrian safety; (iii) smart logistics solutions including in relation to delivery and the use of clean vehicles; (iv) public safety solutions; and (v) health and safety solutions, such as air quality monitoring, We hope these solutions will help cities to tackle the grand challenges of urbanization and climate change, boost sustainable development and enable their digital transformation to smart cities.
More information
To help you to further understand how we may be using your Personal Data as part of the LuxTurrim5G Ecosystem, we have set out below the activities we are carrying out. For each activity, we have set out:
The purpose of the activity and the use of Personal Data
The categories of Personal Data we are collecting
How we collect that Personal Data
Which Partner(s) is the controller of the Personal Data processed in relation to that activity.
If you have any questions about how we collect and use your Personal Data, please see the “Contact Us” section of this Privacy Notice below to find out more information about the controller(s) of your Personal Data including how you can get in touch with them.
1. Research Activity – Vehicle recognition with number plate to identify the emissions in a specific location (Clean Vehicle Wizard)
Purpose of the research activity
Aim is to study and pilot Vediafi’s CVW (Clean Vehicle Wizard) service and especially new emission monitoring options related on that. Idea is to identify specific vehicles and use vehicle specific emission information to generate vehicle emission footprint information, which can be used on various purposes (CO2 monitoring, low emission zones, road pricing, …). Vehicle emission data can be also matched to general CO2 information, which is measured on the same area. For vehicle identification vehicle register plate information by ANPR (Automated Number Plate Recognition) or vehicle id via RF signals will be used. During the pilot, only project team’s own test vehicles are used for tests.
Categories of Personal Data
Purpose of processing
the monitoring the overall air quality levels
enhancing estimated time of arrival (ETA) and estimated time of delivery (ETD)
linking vehicle emissions with transported cargo and recognition location
Sources of Personal Data
Vehicle registration plate information is collected via the camera located in the smart pole directed toward Nokia loading bay using Automatic Number Plate Recognition software. Register plate information of the test vehicles of the testing companies is used to fetch vehicle technical information, mainly emissions, from Vedia CaaS solution.
Controller(s)
Vediafi
Contact
atro.lehtinen@vedia.fi
2. Research Activity – Enhancing security and safety in public environment (Connected Zone)
Purpose of research activity
The purpose is to test and demonstrate Connected Zone which is a public safety application/concept, which uses video feeds of smart poles and bus stops in LuxTurrim5G network and where video feeds and alarms are triggered by the end user with mobile application.
Categories of Personal Data
Location data
Video
Basic contact information (Full name, email-address)
[Other Personal Data that may be voluntarily provided by the individual in an emergency situation]
Purpose of processing
To test and pilot a public safety solution designed to help individuals in emergency situations.
Sources of Personal Data
Location data and basic contact information is collected when you use the app connected with this activity
[Video images and audio recordings are collected using cameras on the smart poles and bus stops situated in and around the Nokia Espoo Campus.]
Controller(s)
Teleste & Nokia
CONTACT
Jani.vare@teleste.com & pekka.wainio@nokia-bell-labs.com
Why do we process your Personal Data?
We will only process your Personal Data if we have a proper reason to do so, the most common reasons for doing so, are the following:
legitimate interest of the controllers - research and development of innovative new technologies in the field of LuxTurrim5G Ecosystem
to comply with our legal and regulatory obligations
when you consent to the processing
to enable us to fulfil a contract we have with you; or
when you consent to the processing; or
to enable us to establish, exercise or defend legal claims.
How do we share your Personal Data?
We, the Partners, may share certain of your Personal Data with other Partners involved in the LuxTurrim5G Ecosystem to help us to complete the testing and pilot activities set out above. We may also share your Personal Data with:
members and affiliates of each Partner’s group of companies and other authorised third parties who process Personal Data for the purposes described in this Privacy Notice;
each Partner’s professional advisors, agents and auditors;
courts, regulators, governments and law enforcement authorities;
[to prospective or actual purchasers of our business and their advisers if we decide to sell, buy, merge or otherwise reorganise our businesses;]
to other third parties if we have your consent to do so.
International transfers of personal data: The servers on which we are storing your Personal Data are currently located in Finland [and Ireland]. The activities may be performed using resources and servers located in various countries around the world. Therefore, your personal data may be transferred across international borders outside the country where it was collected, including to countries outside the European Economic Area (EEA) that do not have laws providing specific protection for personal data or that have different legal rules on data protection. In these cases we use measures to provide adequate protection for your personal data as required by applicable law, for example, by using standard agreements approved by relevant authorities (e.g. the European Commission) and by requiring the use of appropriate technical and organisational information security measures by the third parties receiving your Personal Data.
How do we address data quality and how long do we keep your Personal Data for?
We take reasonable steps to keep the Personal Data we possess accurate and to delete incorrect or unnecessary personal data.
We will always keep your Personal Data for the period required by law in Finland. We will also keep your personal information where we need to do so in connection with legal action or an investigation involving us or one of our group companies. Otherwise, we keep your Personal Data for as long as necessary to fulfil the purposes outlined in this Privacy Notice or otherwise communicated to you. This means that we will retain:
Personal Data obtained from complaints until 31 December 2021 and then confidentially destroy it;
Personal Data obtained in connection with the activities for the duration of the research activities, shortly after which Personal Data that is no longer necessary or relevant for our operations will be de-identified or disposed of securely – the research activities are due to end on 31 December 2021.
How do we keep your Personal Data safe and secure?
The privacy and security of your Personal Data are key considerations in the design and completion of our research activities. We use a variety of security measures and technologies to help protect your Personal Data from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection and privacy laws.
When we use a third-party service provider, they are carefully selected and required to use appropriate measures to protect the confidentiality and security of Personal Data.
The transmission to us of information via the internet or a mobile phone network connection may not be completely secure and any transmission is at your own risk.
What are your rights?
Data privacy laws provide you with a number of rights regarding your Personal Data. Subject to certain restrictions under those laws, you have the following rights:
Access: You have a right to know what Personal Data we hold about you and to obtain a copy.
Data portability: You have a right to obtain in machine-readable format the personal data you have provided to us.
Rectification and erasure: You have a right to have incomplete, incorrect, unnecessary or outdated Personal Data about you deleted or updated.
Withdraw your consent: You have a right to withdraw your consent for our Partners to process your personal data, if the lawful basis for processing by that Partner is based on consent.
Unsubscribe and object: You have a right to unsubscribe from direct marketing messages and to request that we stop processing your Personal Data for direct marketing purposes or we delete your personal data on other grounds. Even if you opt-out from marketing and other communications from the Partners, critical alerts may still be sent to you.
You are able to complain to your local supervisory authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal information. In Finland, this is the Office of the Data Protection Ombudsman (https://tietosuoja.fi).
Contact us
If you have questions or requests about the processing of your Personal Data, need additional information, or would like to exercise any of the rights set out in the “What are your rights?” section above, you can contact Spinverse Oy as the Co-ordinator of the LuxTurrim5G Ecosystem by mail to
LuxTurrim5G Data Privacy
Spinverse Oy
Keilasatama 5
FI-02150 Espoo
Finland
You can also contact the Partners who are controllers of your Personal Data direct. The controllers of your Personal Data are indicated in the “What Personal Data do we collect and what do we use it for?” section above.
