Compal’s technologies are designed to help meet and exceed upcoming regulatory standards, including U.S. NHTSA FMVSS No. 127 pedestrian automatic emergency braking (AEB) requirements (effective September 2029) and UN R152 AEB standards. For more information about our products and services, please visit our website.

As part of the research, development, and validation of our ADAS and autonomous driving technologies, Compal operates test vehicles equipped with various sensors and cameras that record the surrounding driving environment. If you encounter one of our test vehicles (or vehicles operated by authorized partners), please note that the drivers are responsible for safe vehicle operation and compliance with local traffic regulations. These test vehicles may collect certain personal data.

This Privacy Notice (“Notice”) explains how we handle such data in accordance with applicable privacy and data protection laws. Where required by law, this Notice also serves as our notice at collection. It applies solely to personal data collected through our test vehicles.

1. What Personal Data Do We Collect and Why?

Our test vehicles may utilize a range of sensors—including infrared cameras, video cameras, LiDAR, radar, and ultrasonic sensors—to record the surrounding vehicle environment. Depending on your interaction with these vehicles, the following categories of personal data may be collected:

• • General location data (e.g., position relative to the vehicle)
  • Visual and electronic data (e.g., images or video of pedestrians, cyclists, vehicles, license plates, and other road users)

We process this information strictly for the purposes of research, development, validation, and demonstration of safety technologies. For example, we use the data to train and improve algorithms that detect and classify road users, recognize traffic signs, and assist vehicles in reacting safely to their surroundings. Our goal is to improve ADAS and autonomous driving capabilities, including low-visibility pedestrian detection.

We do not seek to identify or uniquely recognize individuals. While certain recordings may incidentally capture identifying details, we do not attempt to re-identify you unless legally required or necessary to verify your identity in connection with a privacy request. We may also use aggregated or anonymized data for legitimate business purposes, unless prohibited by law.

2. Legal Basis for Collection and Processing

Where applicable law does not prescribe a direct legal basis, we rely on our legitimate interests (consistent with privacy laws) in developing technologies that improve overall traffic safety, convenience, and driver/passenger comfort. These development activities benefit both Compal and the broader public by enabling safer mobility solutions.

3. Who May Receive Your Data?

In limited circumstances, personal data collected through test vehicles may be shared with:

• • Development partners and service providers (e.g., IT hosting, algorithm training, and data annotation teams)
  • Authorized parties who require access to perform contracted services for Compal

All such parties are contractually bound to use the data only for defined purposes. Data is shared on a strict “need-to-know” basis. For instance, a radar algorithm partner would only receive relevant radar-related data.

We may also share information as required by law, in response to valid legal requests (such as subpoenas or court orders), or as part of corporate transactions (e.g., mergers or acquisitions). We do not sell, share, or use your personal data for cross-context behavioral advertising or targeted advertising, as defined under applicable laws.

4. How We Protect Your Data

Compal uses appropriate technical and organizational security measures to protect personal data against unauthorized access, alteration, loss, or misuse. We continually update our security measures to meet industry standards and applicable legal requirements.

5. How Long We Keep Your Data

We retain personal data only as long as necessary for the development, validation, and improvement of ADAS and autonomous driving technologies, and to verify software and hardware updates. Once data is no longer needed for these purposes or is no longer required by law, it will be deleted or irreversibly anonymized.

6. Your Rights

Depending on your jurisdiction, you may have rights under applicable privacy laws, which may include:

• • Access and knowledge – Confirm whether we process your personal data and request details about such processing
  • Correction/rectification – Request correction of inaccurate or incomplete data
  • Deletion/erasure – Request that we delete your personal data, subject to legal exceptions
  • Restriction – Request limited processing under certain conditions
  • Objection – Object to processing based on legitimate interests, in certain circumstances
  • Appeal – Appeal our decisions related to your privacy rights

To exercise these rights, or to submit a request, please contact us as outlined below. We will verify your identity before responding, and you may designate an authorized agent to submit a request on your behalf, subject to appropriate verification and permissions.

7. Children’s Data

Our test vehicles and data collection activities are not directed toward individuals under the age of 16, and we do not knowingly collect or sell the personal data of children.

8. Changes to This Notice

We may update or modify this Notice periodically. Any material changes will be highlighted on our website with the updated effective date.

9. Contact Us

If you have questions or concerns about this Notice or how Compal handles personal data, please contact us:

• • Email: info_its@compalusa.com
  • Mail (U.S.): Compal USA (Indiana) Inc. – ITS Division, 1 Technology Way, Logansport IN 46947
  • Mail: Compal Electronics, Inc., Compal Electronics, Inc., No. 16, Lane 35, Jihu Road, Neihu District, Taipei City
  • Phone: +1 574-793-2929

Where applicable, you may also have the right to lodge a complaint with your local data protection authority.