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<!DOCTYPE html> <html lang="en"> <head> <meta charset="UTF-8"> <title> Pony.ai </title> <meta name="keywords" content="autonomous driving, autonomous mobility, autonomous logistics, self driving, pony.ai"> <meta name="description" content="Leading global autonomous driving technology company Pony.ai, Inc. (“Pony.ai”) is pursuing an ambitious vision for autonomous mobility. We aim to bring safe, sustainable, and accessible mobility to the entire world."> <meta http-equiv="X-UA-Compatible" content="IE=Edge"> <meta name="renderer" content="webkit"> <meta content="yes" name="apple-mobile-web-app-capable"> <meta content="default" name="apple-mobile-web-app-status-bar-style"> <meta content="telephone=no" name="format-detection"> <meta name="viewport" content="width=device-width, initial-scale=1, maximum-scale=1, minimum-scale=1.0, user-scalable=no"> <meta name="format-detection" content="telephone=no" /> <meta name="msapplication-tap-highlight" content="no"> <meta name="csrf-token" content="k3XnZXoDIig25QOCwkXalR8LPvUkhTJLdVHTAi9X"> <link href="https://static.cdn.xiaomazhixing.com/images/icon/icon.ico" rel="shortcut icon"> <link href="https://static.cdn.xiaomazhixing.com/images/icon/icon-logo-114.png" rel="apple-touch-icon"> <link href="https://static.cdn.xiaomazhixing.com/images/icon/icon-logo-76.png" sizes="76x76" rel="apple-touch-icon"> <link href="https://static.cdn.xiaomazhixing.com/images/icon/icon-logo-120.png" sizes="120x120" rel="apple-touch-icon"> <link href="https://static.cdn.xiaomazhixing.com/images/icon/icon-logo-152.png" sizes="152x152" rel="apple-touch-icon"> <link rel="stylesheet" href="/css/index.css?id=37148ace55127c78bd3f7dad22873616">  </head> <body> <header class="header "> <a class="icon-wrap en" href="https://pony.ai?lang=en"> <div class="icon icon-logo en"></div> </a> <div class="header-bar"> <div class="header-bar-item"> <a class="" href="https://pony.ai?lang=en">Home</a> </div> <div class="header-bar-item"> <a class="" href="https://pony.ai/tech?lang=en">Technology</a> </div> <div class="header-bar-item"> <a class="" href="https://pony.ai/business?lang=en">Business</a> </div> <div class="header-bar-item"> <a class="" href="https://pony.ai/careers?lang=en">Career</a> </div> <div class="header-bar-item"> <a class="" href="https://ir.pony.ai" target="_blank">Investors</a> </div> <div class="header-bar-item"> <a class="" href="https://pony.ai/press?lang=en">Press</a> </div> <div class="header-bar-item"> <a class="" href="https://pony.ai/story?lang=en">Story</a> </div> <div class="header-bar-item"> <a href="https://static.cdn.xiaomazhixing.com/file/1652065422385/ed5046fc-395a-46cf-a471-1728658f5001/Pony.ai safety report (Mar 31 2022 edit).pdf" target="_blank"> Safety </a> </div> <div class="header-bar-item"> <ul class="lang-btns "> <li> <a href="https://pony.ai/privacyPolicy?lang=en">En</a> </li> <li> <a href="https://pony.ai/privacyPolicy?lang=zh">中文</a> </li> </ul> </div> </div> </header> <div class="fullpage"> <div class="page-content"> <section class="l-section"> <div class="l-section__header"> Privacy Policy </div> <div class="l-section__content"> For employees or job applicants, please click <a href="https://pony.ai/privacyNotice?lang=en">here</a> for privacy disclosure.Effective date: June 5, 2023     This Privacy Policy describes how Pony.ai, Inc. ("Pony.ai," "we," “us,” or "our") handles personal information we collect though our website, mobile application, other digital properties linked to this Privacy Policy, or our other services (collectively, the “Service”).  This Privacy Policy further governs personal information we collect in connection with our marketing activities, through our social media and other activities described in this Privacy Policy. Table of ContentsPersonal information we collectHow we use your personal informationHow we disclose your personal informationYour choicesOther sites and servicesSecurityChildrenChanges to this Privacy PolicyHow to contact usInformation for California residentsInformation for EU residents Personal information we collectInformation you provide to us.  Personal information you may provide to us through the Service or otherwise, includes:<ul><li style="text-align:justify;">Account data including identifiers, such as, for example, your name, email address, phone number, postal address, driver’s license number, username, user avatar, preferences (including preferred trip locations), and trip data; classification information, such as, for example, age, race, ethnicity, gender, and military/veteran status; and any other information that you add to or is associated with your account profile or mobile application.</li><li style="text-align:justify;">Communications we exchange when you contact us with questions, feedback, for support or otherwise, which may include recordings of customer support calls where permitted by law.</li><li style="text-align:justify;">Marketing data, such as your preferences for receiving communications about our products, services, activities and events, information you provide in response to our marketing communications, and information you provide when participating in our events or surveys.</li><li style="text-align:justify;">Inferential data derived from personal information used to generate information about likely preferences or other characteristics about you.</li><li style="text-align:justify;">Other information we may collect which is not specifically listed here but compatible with collection and use as described in this Privacy Policy or as otherwise disclosed at time of collection.</li></ul> Third party sources.  We may combine personal information we receive from you with personal information we obtain from other sources, including:<ul><li style="text-align:justify;">Account holders who order rides or deliveries for you if you do not order them yourself.</li><li style="text-align:justify;">Data licensors, such as demographic data providers.</li><li style="text-align:justify;">Delivery partners, such as certain retailers, restaurants, and others for whom we provide delivery services.  For example, our delivery partners may disclose to us your name and address to facilitate our deliveries to you, and your phone number so we can contact you about your order.</li></ul> Automatic data collection.  We, our service providers, and our business partners may automatically log information that may identify you, your computer or mobile device, your activity on our Service, and our vehicles such as:<ul><li style="text-align:justify;">Usage data, related to your use of our Service, such as your order details, ride pickup and drop-off locations, route, date and time the Service was provided, distance traveled, your interactions with our in-vehicle interfaces, delivery information, and photographs of delivery confirmations.</li><li style="text-align:justify;">Device location data, including precise geolocation data, when you authorize our mobile application to access your device’s precise location, such as your pickup and drop-off location.  We collect device geolocation data when you use our mobile application with location services enabled.</li><li style="text-align:justify;">Vehicle sensor data, such as geolocations of our vehicles when giving rides or making deliveries and data collected from LiDARs, cameras, radar, and other sensors on our vehicles, which we may associate with your personal information.</li><li style="text-align:justify;">Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information derived from your IP address, such as city, state or region.</li><li style="text-align:justify;">Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the online services you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access dates and times, and duration of access.</li><li style="text-align:justify;">Audiovisual data, such as in-vehicle recordings that we make during trips, and audio we may record in our vehicles where permitted by law.</li></ul> Cookies and similar technologies that may identify you. Like many online services, we use following technologies:<ul><li>Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating analytics and online advertising.</li><li>Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.</li><li>Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.</li><li>Software development kits, or SDKs, which are used to incorporate third party computer code into our mobile application that allows our third-party service providers or advertising partners to collect user data directly from the mobile application for a variety of purposes, including, for example, providing us with analytics regarding the use of the mobile application and add features or functionality to the mobile application.</li><li>Analytics and other tools that provide information on how you navigate through and use our Service.</li></ul> How we use your personal informationWe use your personal information for following purposes or as otherwise described at time we collect your personal information: Service delivery.  We use your personal information to:<ul><li style="text-align:justify;">provide, operate, and improve the Service and our business;</li><li style="text-align:justify;">verify your identity;</li><li style="text-align:justify;">establish and maintain your user profile on the Service;</li><li style="text-align:justify;">enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;</li><li style="text-align:justify;">enable personalization of your service account, such as creating quick access to recent pickup locations, accessibility needs, destinations or retail locations for orders, or allowing users to track favorite places;</li><li style="text-align:justify;">automatic payment in connection with using the Service;</li><li style="text-align:justify;">communicate with you about the Service, including by sending ride or delivery status updates, announcements, updates, security alerts, and support and administrative messages;</li><li style="text-align:justify;">understand your needs and interests, and personalize your experience with the Service and our communications;</li><li style="text-align:justify;">provide support for the Service, and monitor and improve our customer support responses and processes; and</li><li style="text-align:justify;">respond to your requests, questions, and feedback.</li></ul> Where individuals are identifiable based on cookies and similar technologies, the technologies may be used to allow operation of our Service (e.g., remember preferences you set or information you entered on a previous page). Research and development.  We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.  This helps us to improve and enhance the safety, security, and accessibility of the Service and develop new features and products.  As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect.  We make personal information into anonymous data by removing information that makes data personally identifiable to you.  We may use this anonymous data and disclose it to third parties for lawful business purposes, including, for example, analyzing and improving the Service and promoting our business. Where individuals are identifiable based on the cookies and similar technologies, the technologies may be used for analytical purposes to help us understand how our Service is performing, being used, and to provide support.  These include cookies and web beacons included in emails we send to track which emails are opened and which links are clicked by recipients.Marketing.  We may send you Pony.ai-related or other direct marketing communications as permitted by law.  You may opt-out of our marketing communications as described in the Opt-out of marketing section below. Compliance and protection.  We may use your personal information to:<ul><li>comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government agencies;</li><li>protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);</li><li>audit our internal processes for compliance with legal and contractual requirements and internal policies;</li><li>enforce the terms and conditions that govern the Service; and </li><li>prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks, identity theft, and vehicle accidents.</li></ul> Retention.  We generally retain personal information to fulfill various obligations and for business purposes.  Obligations can include, for example, satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.  Business purposes can include, for example, retaining personal information that is reasonably necessary to manage our operations, to manage your relationship with us, to satisfy another purpose for which the personal information is collected, or to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information is collected.  Where personal information is used for more than one purpose, we may retain it until the purpose with which the latest period expires. To determine appropriate retention period for personal information, we may consider factors such as amount, nature, and sensitivity of your personal information, potential risk of harm from unauthorized use or disclosure of your personal information, purposes for which we process your personal information and whether we can achieve those purposes through other means, and applicable legal requirements.When we no longer require to retain your personal information, we may either delete it, anonymize it, or isolate it from further processing. How we disclose your personal informationWe may disclose your personal information with following parties or as otherwise described in this Privacy Policy or at time of collection:Delivery partners.  Retailers, restaurants, and others for whom we provide delivery services, with whom we may disclose details about deliveries, such as status and confirmation of deliveries (including photographs of delivery confirmations) or about communications with you about your order.Account holders.  A service account holder that orders a ride or delivery for you will be able to access order or trip information, including real-time precise geolocation data.Other people at the user’s request.  We may disclose your estimated time arrival (ETA) and location with a user when requested by you.Service providers.  Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as information technology, information security, payment processing, hosting and cloud storage, customer relationship management and support, print and mail fulfillment, email delivery, advertising, marketing, data analytics, consumer research, identity verification, and vehicle technology and operations).Professional advisors.  Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of professional services rendered.Authorities and others.  Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.Business transferees.  Acquiring and other relevant parties to business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in Pony.ai (including, in connection with a bankruptcy or similar proceedings).Business partners. Our research partners and other business partners. Your choicesYou have the following choices with respect to your personal information.Access or update your information.  If you have registered for an account with us, you may review and update certain account information by logging into the account.Opt-out of marketing communications.  You may opt out of marketing-related emails by following opt-out or unsubscribe instructions included in the emails, or by <a href="mailto:privacy@pony.ai">contacting us</a>. You may continue to receive service-related and other non-marketing emails.  If you receive text messages from us, you may opt out of receiving further text messages by replying STOP to the text messages.Cookies.  Most browsers let you remove and/or stop accepting cookies from the websites you visit.  To do this, follow instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Service, or the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit <a href="http://www.allaboutcookies.org">www.allaboutcookies.org</a>.Mobile geolocation data.  Users of our mobile application can disable our access to their device’s precise geolocation in their mobile device settings.Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” (DNT) signals to various online services.  Because there is not a universally-agreed upon standard for what a company should do when it detects a DNT signal, we currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit <a href="http://www.allaboutdnt.com">http://www.allaboutdnt.com</a>.Delete your account.  You can request to delete your account by <a href="privacy@pony.ai ">contacting us</a> or selecting Settings – Delete Account in the PonyPilot mobile application (“App”).  When you contact us, we will respond as required by law to honor your verifiable request.  In processing deletion requests, we may retain certain information associated with your account, including for the <a href="#_4i7ojhp">compliance and protection purposes</a> described above or our legitimate business purposes.Local storage. You may be able to limit use of HTML5 cookies in your browser settings. Unlike other cookies, Flash-based local storage cannot be removed or rejected via your browser settings, but you can adjust the settings of your Flash player to block it. Blocking Flash storage may impede the functionality of Flash applications, including those employed by the Service. For more information on Flash local storage visit <a href="https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html">https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html</a>. Other sites and servicesThe Service may contain links to websites, mobile applications, and other online services operated by third parties.  These links are not an endorsement of, or representation that we are affiliated with those third parties.  In addition, our content may be included on web pages or in mobile applications or other online services that are not associated with us.  We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. SecurityWe employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect.  However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.  If you have reasons to believe that your interactions with us are not secure, please immediately contact us at <a href="mailto:privacy@pony.ai">privacy@pony.ai</a> or (844) 769-6995. ChildrenThe Service is not intended for use by anyone under 18 years of age. If we learn we have unknowingly collected personal information through the Service of someone under 18 years of age without consent of their parent or guardian as required by law, we will delete it. Changes to this Privacy PolicyWe reserve the right to modify this Privacy Policy at any time. If we make changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service.  If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service.  Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting).  In all cases, your continued use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy. How to contact us<ul><li style="text-align:justify;">Email: <a href="mailto:privacy@pony.ai">privacy@pony.ai</a></li><li style="text-align:justify;">Calling: (844) 769-6995, a toll-free number</li></ul> Information for California residents Scope.  This section applies only to California residents and their households (referred collectively as “California residents”).  This section describes how we collect, use, and disclose Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act, as amended (the “CCPA”), and their rights with respect to their Personal Information.  Unless preempted by a superseding law, this section will apply in addition to the other sections of this Privacy Policy applicable to California residents.  For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA.  In some cases, we may provide a different privacy notice to certain categories of California residents, such as employees and job applicants, in which case that notice will apply instead of this section.Personal Information.  Please refer to <a href="#_kgcv8k">Personal information we collect</a> and <a href="#_26in1rg">How we use your personal information</a> for Pony.ai’s data collection, use, and retention.Sensitive Personal Information.  CCPA provides a type of personal information as “sensitive personal information.”  Pony.ai may collect and use following categories of sensitive personal information:<ul><li>Account credentials, such as financial account information (e.g., debit or credit card information) and associated log-in credentials that you have provided or is associated with your account profile in connection with the Service to provide, operate, and improve the Service and our business.</li><li>Precise geolocation data to access your precise geolocation data to provide the Service (e.g., designated pick up or drop off locations, trip or route determination, etc.) and for internal research and development purposes.</li><li>Personal health information, such as information relating to physical impairments, may be collected by Pony.ai for internal research and development purposes and to improve quality and safety of the Service.</li><li>Racial and ethnic origin. Pony.ai may ask users to provide certain demographic information for internal research and development purposes to ensure proposer user research.</li></ul> We do not collect or use sensitive personal information for purposes beyond those described in this Privacy Policy. Pony.ai does not sell or, for cross-context behavioral advertising, share sensitive personal information. Your California privacy rights. As a California resident, you have the rights listed below and may exercise the rights by submitting a verifiable consumer request. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.<ul style="list-style-type:disc;"><li style="text-align:justify;">Know/Access.  You can request the following information about how we have collected and used your Personal Information during the past 12 months:<ul><li style="text-align:justify;">Categories of Personal Information that we have collected.</li><li style="text-align:justify;">Categories of sources from which we collected Personal Information.</li><li style="text-align:justify;">Categories of Personal Information we have disclosed about you for a business purpose and categories of recipients to which it was disclosed.</li><li style="text-align:justify;">Categories of Personal Information that we sold or, for cross-context behavior advertising, shared and categories of third parties to whom Personal Information was sold or, for cross-context behavior advertising, shared.</li><li style="text-align:justify;">Categories of third parties to whom Personal Information was disclosed for a business purpose.</li><li style="text-align:justify;">Business or commercial purposes for collecting, selling, or, for cross-context behavior advertising, sharing Personal Information.</li><li style="text-align:justify;">Specific pieces of Personal Information collected.</li></ul></li><li style="text-align:justify;">Correct.  You can ask us to correct inaccurate Personal Information we have collected about you.</li><li style="text-align:justify;">Delete.  You can ask us to delete Personal Information we have collected from you.  Please be aware that certain information we have collected from you may still be retained for legal, accounting, security, information technology backup, and anti-fraud reasons, as well as for solely internal uses reasonably aligned with your expectation based on your relationship with us and compatible with the context in which you provided the information.</li><li style="text-align:justify;">Nondiscrimination.  You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.</li></ul> How to exercise your rights.  You may submit requests to exercise your California privacy rights described above as follows:<ul style="list-style-type:disc;"><li style="text-align:justify;">Request to know/access, correct, and delete. You may submit requests to:<ul><li style="text-align:justify;">emailing: <a href="mailto:privacy@pony.ai">privacy@pony.ai</a></li><li style="text-align:justify;">calling: (844) 769-6995, a toll-free number</li></ul></li></ul>These requests can be made for personal information of a consumer but not of a household.<ul style="list-style-type:disc;"><li style="text-align:justify;">Request to opt out of sale and, for cross-context behavior advertising, sharing.  You may opt out of sales or, for cross-context behavior advertising, sharing via cookies or tracking technologies through an opt-out preference signal or through our Cookie Settings. If you would like to opt out of sales and, for cross-context behavior advertising, sharing other than through cookies or other online tracking technologies, you can do so by submitting a request through the email or toll-free number provided above.</li><li style="text-align:justify;">Request to limit use and disclosure of Sensitive Personal Information.  We do not use Sensitive Personal Information for the purpose of inferring characteristics about you.  For this reason, Sensitive Personal Information we collect are not subject to a limit use request and, therefore, we do not offer a way for you to submit such a request.</li></ul> We will need to verify your identity to process your requests and reserve the right to confirm your California residency.  Authentication into your Pony.ai account (if applicable), government identification or other information may be required.  Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465.  If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorized agent permission to submit the request.We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.Personal information that we collect, use, and disclose.  The chart below describes Personal Information we collected during the 12 months preceding the effective date of this Privacy Policy by reference to the categories of Personal Information specified in the CCPA (California Civil Code § 1798.140).  Information you voluntarily provide to us, such as in free form webforms, may contain other categories of personal information not described below.<figure class="table"><table><tbody><tr><td style="width:85.25pt;">Statutory category  </td><td style="width:1.5in;">Source  (See entitled <a href="#_kgcv8k">Personal information we collect</a> above for descriptions)</td><td style="width:121.5pt;">Personal Information we collect in this category  (See <a href="#_kgcv8k">Personal information we collect</a> above for descriptions)</td><td style="width:85.5pt;">Disclosure, for a business purpose, to</td><td style="width:67.5pt;">Cross-Context Behavioral Advertising</td></tr><tr><td style="width:85.25pt;">Identifiers</td><td style="width:1.5in;">You Third party sourcesAutomatic collection</td><td style="width:121.5pt;">Account dataDevice data </td><td style="width:85.5pt;">Business partners, Delivery partners, Service providers</td><td style="width:67.5pt;">None</td></tr><tr><td style="width:85.25pt;">Personal Records (personal information described in 1798.80(e) of the California Civil Code) </td><td style="width:1.5in;">YouThird party sources</td><td style="width:121.5pt;">Account dataCommunicationsMarketing data</td><td style="width:85.5pt;"> Business partners, Delivery partners, Service providers</td><td style="width:67.5pt;">None</td></tr><tr><td style="width:85.25pt;">Commercial Information</td><td style="width:1.5in;">YouThird party sourcesAutomatic Collection</td><td style="width:121.5pt;">Account dataCommunicationsMarketing dataUsage dataVehicle sensor dataOnline activity data</td><td style="width:85.5pt;"> Business partners, Delivery partners, Service providers</td><td style="width:67.5pt;">None</td></tr><tr><td style="width:85.25pt;">Internet or Network Information</td><td style="width:1.5in;">Automatic collection</td><td style="width:121.5pt;">Device dataMarketing dataOnline activity data</td><td style="width:85.5pt;"> Business partners, Delivery partners, Service providers</td><td style="width:67.5pt;">None</td></tr><tr><td style="width:85.25pt;">Geolocation Data (including Precise Geolocation Data)</td><td style="width:1.5in;">Automatic collection</td><td style="width:121.5pt;">Device location dataVehicle sensor data</td><td style="width:85.5pt;"> Business partners, Delivery partners, Service providers</td><td style="width:67.5pt;">None</td></tr><tr><td style="width:85.25pt;">Sensory Data, including audio and visual data</td><td style="width:1.5in;">Automatic collection</td><td style="width:121.5pt;">Usage dataAudiovisual data</td><td style="width:85.5pt;">Business partners, Delivery partners, Service providers</td><td style="width:67.5pt;">None</td></tr><tr><td style="width:85.25pt;">Inferences</td><td style="width:1.5in;">N/A</td><td style="width:121.5pt;">May be derived from any category of personal information excluding sensitive personal information. </td><td style="width:85.5pt;"> Business partners, Delivery partners, Service providers</td><td style="width:67.5pt;">None</td></tr></tbody></table></figure>Purposes.  We describe business and commercial purposes for which we collect this Personal Information in the section above entitled <a href="#_26in1rg">How we use your personal information</a>.Disclosure.  We disclosed this Personal Information to categories of third parties described in the section above entitled <a href="#_49x2ik5">How we disclose your personal information</a>.Sale or, for cross-context behavior advertising, sharing of Personal Information. We have not sold or, for cross-context behavior advertising, shared your personal information in the preceding 12 months. Privacy Policy for EU ResidentsLast update: February 4, 2025<ol><li>Introduction</li></ol>At Pony.ai Europe SARL (“we”, “us”, “our”), the protection of personal information is a core priority. This data protection notice provides you with more information on the processing of personal data collected through our vehicles, which are deployed for testing purposes on public roads and private facilities to advance autonomous and connected vehicle technologies.The primary purpose of our data collection and processing is to improve road safety for all users, including those relying on autonomous vehicle technology and the broader public. By capturing and analyzing data from diverse real-world traffic scenarios, we aim to enhance the reliability, accuracy, and safety of advanced driver-assistance systems (ADAS) and autonomous vehicle (AV) functionalities. These systems are critical to reducing accidents, protecting vulnerable road users, and fostering trust in next-generation mobility solutions.Specifically, the data collected and processed allows us to:<ul><li>Develop and refine algorithms that recognize and respond to complex traffic situations, such as pedestrian movements and interactions with other road users.</li><li>Analyze and predict the behavior of pedestrians, including their gaze direction, to ensure the technology can anticipate and respond to potential movements.</li><li>Validate and enhance systems designed to identify vehicles, cyclists, and other road participants, ensuring safe and efficient operation under real-world conditions.</li></ul>This work supports our broader goal of creating autonomous vehicles capable of safe and seamless integration into public traffic systems, ultimately contributing to safer roads for all.<ol><li>Data controller & Data Protection Officer</li></ol>The controller responsible for processing personal data collected by our vehicles, is:Pony.ai Europe S.à.R.L 9, avenue des Hauts-Fourneaux, L-4362, Esch-sur-Alzette, LuxembourgEmail: <a href="mailto:privacy@pony.ai">privacy@pony.ai</a>For any inquiries regarding this data protection notice or the processing of your personal data, please contact our Data Protection Officer (“DPO”): Z5 S.à.R.L.-SEmail: <a href="mailto:yoann@z5.lu">yoann@z5.lu</a> Postal address:21, boulevard F.W. Raiffeisen, L-2411, Luxembourg, Luxembourg. <ol><li>Specific information on the categories of personal data, purposes and legal basis for the processing, and retention periods</li></ol>The table below shows a description of all personal data being processed and from which source they originate if not collected from you directly, the purposes for which we process such personal data, on which legal basis we rely to do so, and the respective retention periods.  <figure class="table"><table><tbody><tr><td>Categories of personal data and their source</td><td>Purposes of processing</td><td>Legal basis of processing </td><td>Retention period</td></tr><tr><td rowspan="2">External cameras and advanced vehicle sensors and technologies (LIDAR, radar, ultrasonic sensors and other systems to detect static and dynamic objects), capture surroundings and process:<ul><li>Video recordings and images, of road users (e.g., vehicles, cyclists, pedestrians), which also record infrastructures, road signs, and other objects in the vehicle’s surroundings.</li></ul> <ul><li>Spatial data: GPS location of the vehicle, timestamp, and environmental context.</li></ul>  <ul><li>Location data: precise, real-time location of the vehicle in relation to other dynamic or static objects, and geolocation of other road users (e.g., vehicles, cyclists, pedestrians).</li></ul></td><td>To enhance our vehicle's ability to perceive and navigate real-world traffic scenarios.To train and refine algorithms for recognizing and responding to various road and environmental conditions.To optimize safety for road users including third parties and the vehicle’s users. </td><td>Necessary for the purposes of our legitimate interests: <ul><li>to carry out research and development activities in the context of innovation and safe manner advanced driver-assistance systems (ADAS) and autonomous and connected vehicle technologies.</li><li>to improve and validate in a safe manner said systems and technologies.</li><li>to assess and validate the performance of safety systems deployed by us and ensuring compliance with international and national safety and operational standards.</li><li>to fulfil our duty of care and safety for road users including third parties and the vehicle’s users. </li></ul></td><td rowspan="5">Personal data will be retained no longer than necessary for the purposes outlined here. </td></tr><tr><td>As a secondary purpose, exclusively in the events of damages to, or theft of the vehicle, or liability claims, to defend our legal interests.</td><td>Necessary for the purposes of our legitimate interest to litigate and/or bring, exercise or substantiate a legal claim.</td></tr><tr><td><ul><li>Short-term behavioral indicators and patterns of pedestrians and other road users, such as direction of gaze, posture, and movements relative to our vehicle. </li></ul>  <ul><li>Interactions: Proximity and interaction with other road users, including potential crossing behavior.</li></ul></td><td>To improve predictive algorithms to anticipate pedestrian and other road users’ actions.To ensure our vehicle's decision-making prioritizes the safety of vulnerable road users in dynamic traffic environments.To protect pedestrians and other road users.</td><td>Necessary for the purposes of our legitimate interests<ul><li>to carry out research and development activities in the context of innovation and safe manner advanced driver-assistance systems (ADAS) and autonomous and connected vehicle technologies.</li><li>to improve and validate in a safe manner said systems and technologies.</li><li>to assess and validate the performance of safety systems deployed by us and ensuring compliance with international and national safety and operational standards.</li></ul></td></tr><tr><td rowspan="2"><ul><li>Third party vehicle performance data: License plate numbers (when visible), vehicle types, movement patterns of other road users (e.g., vehicles and cyclists)</li></ul> </td><td>To evaluate system performance and interaction with other road users. To validate communication and interaction between our vehicle and other road participants.To optimize traffic safety and efficiency by refining vehicle responses to traffic dynamics.</td><td>Necessary for the purposes of our legitimate interests<ul><li>to carry out research and development activities in the context of innovation and safe manner advanced driver-assistance systems (ADAS) and autonomous and connected vehicle technologies.</li><li>to improve and validate in a safe manner said systems and technologies.</li></ul>to assess and validate the performance of safety systems deployed by us and ensuring compliance with international and national safety and operational standards.</td></tr><tr><td>As a secondary purpose, exclusively in the event of damages to, or theft of the vehicle, or liability claims, to defend our legal interests.</td><td>Necessary for the purposes of our legitimate interest to litigate and/or bring, exercise or substantiate a legal claim.</td></tr></tbody></table></figure><ol><li> Legal basis for processing </li></ol>The processing of personal information collected through Pony.ai vehicles is conducted in compliance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR). Our personal data processing activities are necessary for the purpose of protecting our legitimate interests (Article 6(1)(f) GDPR). This legal basis is supported by the following considerations:<ol><li>Advancing road user safety</li></ol><ul><li>The primary purpose of data processing is to develop and improve advanced driver-assistance systems (ADAS) and autonomous vehicle technologies, which are pivotal in reducing traffic accidents and fatalities.</li><li>These systems serve the broader public interest, as they aim to significantly reduce traffic accidents, enhance road safety, and protect vulnerable road users (e.g., pedestrians, cyclists).</li><li>The broader societal benefits of safer roadways and reduced road casualties outweigh the minimal impact on individual privacy, particularly given our robust anonymization and data protection measures.</li></ul><ol><li>Supporting innovation in autonomous vehicle technology</li></ol><ul><li>Processing personal data enables the development of algorithms that train autonomous vehicles to operate safely and effectively in complex, real-world traffic scenarios. </li><li>This includes analyzing the behavior of road users, such as pedestrian gaze direction, recognizing static and dynamic objects (e.g., vehicles, road signs, infrastructure), and adapting to diverse driving conditions.</li><li>Innovation in autonomous vehicles represents a key societal advancement, contributing to safer, more efficient transportation systems.</li></ul><ol><li>Ensuring compliance with safety standards and regulatory requirements</li></ol><ul><li>The data collected is instrumental for validating the performance of safety systems and ensuring compliance with international and national safety and operational standards.</li><li>Testing under real-world conditions is necessary to meet evolving regulatory requirements and establish public trust in autonomous vehicle technologies.</li></ul><ol><li>Minimization of intrusion</li></ol><ul><li>Personal data is processed in ways that minimize impact on individual privacy. This includes measures such as:<ul><li>Anonymization and pseudonymization of data as soon as practicable after the data is collected.</li><li>Processing data at a level of abstraction that focuses on generalized behaviors (e.g., recognizing "pedestrian crossing" rather than identifying specific individuals).</li></ul></li><li>Data is used solely for the purposes of research, development, and safety validation and is not processed or used for marketing or unrelated purposes.</li></ul><ol><li>Alignment with GDPR principles</li></ol><ul><li>Processing activities are conducted transparently, with clear documentation on the purposes and safeguards.</li><li>Robust security measures, such as encryption and restricted access, protect data integrity and confidentiality.</li><li>Data subjects are provided with opportunities to exercise their GDPR rights, including access, rectification, and objection to processing.</li></ul>Innovation in autonomous vehicles represents a key societal advancement, contributing to safer, more efficient transportation systems. The broader societal benefits of safer roadways and reduced road casualties outweigh the minimal impact on individual privacy, particularly given our robust anonymization and data protection measures.  <ol><li>Data transfers and recipients</li></ol>To advance the development and validation of autonomous vehicle technologies, Pony Europe SARL and Pony.ai US exclusively share personal information with a limited number of carefully selected contractors and service providers involved in the research, development, and testing of autonomous vehicle systems. Contractors are engaged solely for specific purposes, such as algorithm development, data analysis, and system validation. All data transfers are conducted in compliance with the GDPR and relevant national laws, with strict safeguards in place to ensure data protection. No data is shared with third parties for purposes unrelated to the development of autonomous vehicle technologies. Identifiable personal information is anonymized or pseudonymized wherever possible before sharing.The table below shows the categories of recipients to whom personal data are transferred, where they are located, whether an adequacy decision is in place or if other appropriate safeguards are in place if needed, and how to obtain a copy thereof.<figure class="table"><table><tbody><tr><td>Categories of recipients</td><td>Location</td><td>Categories of personal data</td><td>Adequacy decision or other safeguards</td><td>How to obtain a copy of the implemented safeguards</td></tr><tr><td>Pony.ai US, only occasionally in case of exceptionally high-end support requests, access to a very specific dataset can be granted to Pony.ai US.</td><td>US</td><td>Very specific and limited datasets from one or more categories as mentioned under section 3.</td><td>EU standard contractual clauses as provided by the European Commission (Article 46(2) GDPR)</td><td>Please contact our DPO should you wish to obtain a copy of the standard contractual clauses implemented.</td></tr><tr><td>Authorized contractors and service providers, such as IT and telecom service providers </td><td>Luxembourg   </td><td>All categories of data as mentioned under section 3</td><td>Not applicable</td><td>Not applicable</td></tr><tr><td>Data analysis service providers, such as data labeling service providers</td><td>PolandBosniaUS</td><td>All categories of data as mentioned under section 3</td><td>EU standard contractual clauses as provided by the European Commission (Article 46(2) GDPR)</td><td>Please contact our DPO should you wish to obtain a copy of the standard contractual clauses implemented.</td></tr><tr><td>Law enforcement authorities (only in the case of a lawful request)</td><td>Luxembourg</td><td>Video recordings and images, location data, spatial data, third party vehicle performance data</td><td>Not applicable</td><td>Not applicable</td></tr></tbody></table></figure> Data shared between Pony Europe SARL, Pony.ai US, contractors and service providers is protected using industry-leading security measures, including:<ul><li>Encryption: Data is encrypted during transmission to prevent unauthorized access.</li><li>Access Controls: Only authorized personnel with a need-to-know basis can access the data.</li><li>Monitoring and Auditing: Regular monitoring of data access and processing activities ensures compliance with contractual obligations and legal standards.</li><li>Contractors are required to adhere to our rigorous data protection standards, including maintaining segmented IT systems to avoid unauthorized access and data breaches.</li></ul> We maintain oversight of all data sharing activities, conducting regular audits and assessments of contractors’ compliance with GDPR and contractual requirements. In the event of a data breach, contractors are obligated to notify Pony.ai immediately and cooperate fully in response efforts.  <ol><li>Your Rights </li></ol>You have the following rights under applicable data protection laws:<ul><li>Right of access</li></ul>You may request to receive confirmation as to whether or not we hold personal data concerning you, and to receive a copy of your personal data we hold about you to the extent such copy does not adversely affect the rights and freedoms of others. As our systems do not identify individuals per se and mostly process data in a de-identified manner, we may not be able to identify you in which case we will inform you accordingly. We only hold personal data for a very limited period of time. Once erased, access to personal data can no longer be granted. <ul><li>Right to rectification</li></ul>You may request to have any incomplete, or inaccurate data we hold about you corrected. As our systems do not identify individuals per se and process data in a de-identified manner, we may not be able to identify you in which case we will inform you accordingly. For the same reason, rectification is typically only feasible through deletion. We only hold personal data for a very limited period of time. Once erased, personal data can no longer be rectified.<ul><li>Right to erasure </li></ul>You may request the deletion of the personal data we hold about you if: <ul><li>if that personal data is no longer necessary for the purpose of collection, </li><li>you have successfully exercised your right to object to processing and no overriding legitimate grounds exist (see below), </li><li>that personal data was processed unlawfully, </li><li>that personal data have to be erased for compliance with a legal obligation in EU or national laws to which we are subject. </li></ul>As our systems do not identify individuals per se and process data in a de-identified manner, we may not be able to identify you in which case we will inform you accordingly. Given our de-identified processing, implementing erasure may require additional identifying details, such as the date, time, and location of the event. We may request to provide this information to assist us in locating relevant personal data.<ul><li>Right to object</li></ul>You may object to the processing of the personal data we hold about you based on legitimate interests. To exercise this right, we may request to provide grounds relating to your particular situation. While we strive to honor all objections, processing may continue if we demonstrate compelling legitimate grounds, or the processing is required for the establishment, exercise, or defense of legal claims.<ul><li>Right to restriction of processing</li></ul>Under certain conditions, you may also request us to restrict the processing of the personal data we hold about you, for example if the accuracy of your personal data is contested by you or if the processing is unlawful. As our systems do not identify individuals per se and process data in a de-identified manner, we may not be able to identify you in which case we will inform you accordingly.In the event that you wish to exercise any of your rights as conferred under the GDPR, as outlined above, you can contact our DPO (using the contact details provided above). Please specify your request as precisely as possible, taking into account the circumstances of the case, including the date, time, and location of the interaction with our vehicle. Any additional contextual information would also be appreciated in order to identify the data in question. We will evaluate your request and take appropriate measures. In cases where data cannot be identified or located, we will inform you of the limitations and provide further guidance.Further to the rights listed above, you have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (“CNPD”) (link: <a href="https://cnpd.public.lu/fr.html">https://cnpd.public.lu/fr.html</a>). If you reside in a different EU Member State, you may also lodge a complaint with your local data protection authority.  <ol><li>Effect of this data protection notice and its changes</li></ol>This data protection notice is effective as of [1 December 2024]. We may update this notice periodically to reflect changes in legal requirements, advancements in technology, or updates to our data processing practices. The latest version will always be accessible on our website [<a href="https://pony.ai/privacyPolicy?lang=en">https://pony.ai/privacyPolicy?lang=en</a>], which can also be accessed through a QR code on our vehicles.  <ol><li>Contact us</li></ol>If you have questions about this data protection notice or this processing, please do not hesitate to contact us directly through the contact details provided above. </div> </section> </div> <footer> <div class="footer-bar"> <a class="icon-wrap en" href="https://pony.ai?lang=en"> <div class="icon icon-logo-color en"></div> </a> <div class="footer-menus"> <div class="footer-menu"> <a href="https://pony.ai/tech?lang=en"> Technology </a> </div> <div class="footer-menu"> <a href="https://pony.ai/careers?lang=en"> Career </a> </div> <div class="footer-menu"> <a href="https://pony.ai/press?lang=en"> Press room </a> </div> <div class="footer-menu"> <a href="https://pony.ai/story?lang=en"> Our Story </a> </div> </div> </div> <div class="footer-link"> <div class="footer-link__ld"> <a href="https://twitter.com/ponyai_tech?lang=en" target="_blank" class="footer-contact-item"> </a> <a href="https://www.linkedin.com/company/pony-ai/mycompany/" target="_blank" class="footer-contact-item"> </a> <a href="https://www.youtube.com/channel/UCOPPNGapFe-g7BUVIHFt4Dg" target="_blank" class="footer-contact-item"> </a> <a href="https://www.facebook.com/PonyAITech/?view_public_for=113349486881463" target="_blank" class="footer-contact-item"> </a> <a href="https://medium.com/pony-ai-blog" target="_blank" class="footer-contact-item"> </a> <a class="footer-contact-item" href="javascript:;"> <div class="footer-mail"> contacts@pony.ai media@pony.ai </div> </a> </div> <div class="footer-link__rd"> <div class="footer-relate-item"> ©2025 Pony.ai </div> <a href="/firstresponders" target="_blank" class="footer-relate-item"> First Responders </a> <a href="https://static.cdn.xiaomazhixing.com/file/1652065422385/ed5046fc-395a-46cf-a471-1728658f5001/Pony.ai safety report (Mar 31 2022 edit).pdf" target="_blank" class="footer-relate-item"> Safety Report </a> <a href="https://pony.ai/privacyPolicy?lang=en" target="_blank" class="footer-relate-item"> Privacy Policy </a> <a href="https://pony.ai/termService?lang=en" target="_blank" class="footer-relate-item"> Terms of Service </a> </div> </div> </footer></div> <script type="text/javascript" src="https://pony.ai/common/js/jquery-3.6.0.min.js"></script> <script> (function(){ var prevScrollpos = window.pageYOffset; function checkHeader () { var currentScrollPos = window.pageYOffset; if (currentScrollPos === 0) { $('.header').removeClass('active hidden'); } else if (prevScrollpos >= currentScrollPos) { $('.header').removeClass('hidden').addClass('active'); } else { $('.header').removeClass('active').addClass('hidden'); } prevScrollpos = currentScrollPos; } function addScrollListener () { window.onscroll = function() { checkHeader(); } } $(document).ready(function(){ checkHeader(); addScrollListener(); }); })(); </script><script> (function() {})() </script> </body> </html>